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Sanctions screening for Accountants — 2026 AUSTRAC Guide

If your accounting practice provides a designated service from 1 July 2026, you must screen every customer against the DFAT autonomous sanctions list and the UN Security Council consolidated list before you start the work, and keep screening during the relationship. This matters for accountants because criminals can use firms that help with entity structures, client money flows, transactions, or business set-up to move value to sanctioned people or entities. If you provide services to a sanctioned person, that is a strict-liability criminal offence, and wider AML/CTF breaches can also expose your practice to AUSTRAC enforcement and civil penalties up to $33.5 million per contravention.

Your AML/CTF obligations

  1. 1. AUSTRAC enrolment
  2. 2. Compliance officer
  3. 3. ML/TF risk assessment
  4. 4. AML/CTF program
  5. 5. Customer due diligence
  6. 6. Sanctions screening
  7. 7. Suspicious matter reporting
  8. 8. Record keeping (7 years)
  9. 9. Staff training

For an accounting practice, sanctions screening is not the same as ordinary identity checking. Verifying a client’s driver licence or company details through ASIC does not tell you whether the client, a director, trustee, beneficial owner, appointor or controller is subject to Australian sanctions. Screening means checking relevant names against the DFAT and UN lists before you provide the designated service, then repeating checks when something changes or while the client relationship continues. If you act for companies, trusts, SMSF structures, overseas-owned groups or clients using nominees, screening needs to go beyond the person who signs your engagement letter.

What an accountant should do in practice

  • Work out whether the engagement is a designated service. Tax return preparation alone is generally not a designated service for accountants.
  • Collect the names you need to screen before starting: the client, directors, trustees, beneficial owners holding 25% or more, and anyone exercising effective control.
  • Screen those names against the DFAT autonomous sanctions list and the UN Security Council consolidated list before providing the service.
  • If there is a potential match, stop and escalate it inside the firm before doing any further work or moving any money or assets.
  • Re-screen when ownership, control, directors, trustees, countries involved, or the scope of work changes, and at set intervals for ongoing clients.

Do not treat this as a one-off onboarding check

For accountants, sanctions risk often changes mid-engagement. A client may insert a new shareholder, move funds through an overseas entity, appoint a new trustee, or ask you to assist with a transaction involving another country. Each of those changes can require re-screening before you continue.

The main mistakes for accounting firms are practical ones. One is assuming sanctions screening only matters for international clients. An Australian company or trust can still be owned or controlled by a sanctioned person. Another is screening only the entity name and not the beneficial owners or controllers behind it. A third is relying on your software vendor without checking what lists are actually covered, how often they update, and how false positives are reviewed. If your practice helps set up companies, manage trust structures, handle client funds, or support business sales, your screening process needs to be built into client acceptance and file-opening, not left to ad hoc checks.

Practical tips for small accounting practices

  • Add sanctions screening to your new-client checklist and your annual client review checklist.
  • Create a trigger list for re-screening: change of directors, change of trustee, new beneficial owner, overseas payment request, asset sale, or restructuring work.
  • Keep a clear record of who was screened, which list was used, the date, the result, and who approved any match review.
  • Train admin staff and accountants to pause the matter if a client pushes to proceed before screening is cleared.
  • If a match is unclear, do not guess from a name alone — review identifiers carefully and escalate internally.

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Frequently asked questions

Do I need to screen clients if my firm only does tax returns and BAS work?
Not always. Tax return preparation alone is generally not a designated service for accountants, so AML/CTF obligations are not triggered just because you prepare returns or BAS statements. You need to look at the actual service you provide, especially if your firm also helps with entity formation, transactions, client money, or other designated services.
Who exactly do I screen for a company or trust client?
Screen more than the entity name. For a company, that usually includes the company, its directors, and beneficial owners who hold 25% or more or otherwise exercise effective control. For a trust, screen the trustee and the natural persons who ultimately own or control the structure, which may include appointors, controllers, or beneficial owners depending on the trust arrangement.
What if I get a possible name match on a sanctions list?
Do not proceed with the designated service until the match is resolved. Review other identifiers such as date of birth, address, country, entity details, and control information, then escalate the matter under your AML/CTF procedures. Providing services to a sanctioned person is a strict-liability criminal offence, so a possible match cannot be waved through because the client is in a hurry.
Do I have to buy sanctions screening software?
The law requires effective screening, not a particular product. A small practice may use a manual process for low volumes, but it must be reliable, documented, and repeated during the relationship when needed. If you use software, check that it screens against the DFAT autonomous sanctions list and the UN Security Council consolidated list and that your staff know how to handle alerts.
How often should I re-screen an existing accounting client?
Re-screen when something material changes and during the relationship. For accountants, common triggers are a new shareholder, director or trustee, a restructure, an overseas payment instruction, a business sale, or a move into a higher-risk jurisdiction. Your AML/CTF program should set a regular review cycle as well, so ongoing clients are not left unchecked for years.

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