In this month’s BK Pod, we cover two key developments affecting the bookkeeping profession. First, we provide an update on the proposed Tranche 2 Anti-Money Laundering (AML) reforms and what they may mean for BAS agents and bookkeepers. A practical decision-tree approach is discussed to help practitioners determine whether their services may trigger a requirement to register with AUSTRAC. The discussion focuses on three potential “hotspots”: acting as a director or trustee for a client, providing a registered office or business address, or receiving, holding or controlling a client’s money as part of executing transactions. Importantly, it is clarified that simply preparing ABA payment files or having limited authority where the client still approves payments will not generally constitute control of client funds.

The episode also explores recent developments following the Tax Ombudsman’s report into ATO agent services. The report identified several areas where the ATO’s engagement with tax and BAS agents could be improved, particularly in relation to digital services, phone support and overall interaction with the agent community. In response, the ATO has acknowledged many of the concerns raised and committed to addressing the issues through a structured consultation process.

As part of this response, a new consultation forum known as the Tax Practitioners Implementation Consultation (TPIC) group has been established. The group brings together ATO representatives, professional associations and practitioners to work through the report’s recommendations and develop practical improvements. While meaningful reform will take time, the early meetings indicate a clear commitment to improving systems and strengthening the relationship between the ATO and the agent community.

Key Takeaways

• AML Tranche 2 reforms may require some BAS agents or bookkeepers to register with AUSTRAC, depending on the services they provide.
• Three key AML “hotspots” include acting as a director/trustee, providing a registered business address, or controlling client funds during transactions.
• Preparing ABA files or payment batches alone does not constitute control of client funds, meaning AUSTRAC registration is generally not required in those cases.
• The Tax Ombudsman’s report identified major issues in ATO agent services, particularly digital systems and phone support.
• The ATO has established the TPIC consultation group to work with industry bodies and agents to implement improvements and address the report’s recommendations.