Acis AML/CTF Changes from 1 July 2026 

Current as of: 26 June 2026.

From 1 July 2026, Australia’s Anti Money Laundering and Counter Terrorism Funding (AML/CTF) regime expands to include certain trust and company services.

For both Acis and our clients, this means new compliance obligations for specific products and services.

Our approach is to keep things as streamlined as possible whilst maintaining the integrity of the regime: where genuine compliance already exists, we rely on it – where it doesn’t, we support it within the order process.

What’s changing? 

The Tranche 2 reforms extend AML/CTF obligations to professional services involved in activities at higher-risk for money laundering, terrorism financing, or proliferation financing, including: 

  • Company, trust, and self-managed super fund formations 
  • Trust and SMSF mendments resulting in changes in control or ownership 

For Acis, this means some products will now be classified as  Designated Services and require AML/CTF compliance. See which services are included in the FAQ section at the end of this article. 

How it works with Acis 

From 1 July, when ordering a Designated Service with Acis, there are two pathways: 

1. You’ve already completed all required AML/CTF Compliance 

If your firm is an enrolled  reporting entity under the AML/CTF regime and has already completed the required compliance and checks, you can confirm this at the time of order. 

This includes: 

  • Being enrolled with AUSTRAC for the purposes of AML/CTF laws 
  • Maintaining appropriate AML/CTF systems, controls, and procedures 
  • Conducting customer identification and verification (including beneficial ownership checks where appropriate) for all relevant parties using reliable and independent data or information in accordance with AML/CTF Laws. 

Where you consent to Acis relying on your compliance, and are willing to provide copies of verification data if requested, there is no duplication and no additional fees.  This reflects and supports how many of our clients already operate, particularly where AML processes are part of existing workflows. 

2. Add identification and verification to your order 

If the above doesn’t apply, Identification and Verification will be completed as part of your Acis order. 

In this case: 

  • Checks over relevant Entities and Individuals are completed digitally through our verification partner, First AML 
  • The individuals who need to complete Identification & Verification will receive a secure link, directly from First AML, to complete the process directly 
  • Results flow back into the Acis order process  

Applicable AML/CTF fees will be included where this pathway is selected. 

While we support identification and verification within the order, your firm remains responsible for its own AML/CTF obligations and governance processes. 

What this means for your workflow 

For most of our clients, the impact will be limited to selecting a compliance pathway (Option 1 or 2 above) at the time of order. 

Orders including Identification and Verification cannot be processed by us until all required verification requests have been successfully completed.

Pricing

Identity and Verification fees will apply on a per-party basis. The total fees for any specific order will therefore depend on the number of components that require verification as part of that order. 

Component Type Acis Fee (excl. GST) 
Individual  $9.00
Company  $58.50
Trust/SMSF $4.50

Pricing Examples

Example 1: Company + Trust

Company Order:

  • Company Name: Smithsters Pty Ltd
  • Directors: John Smith & Mary Smith
  • Shareholders: John Smith & Mary Smith

Trust Order:

  • Trust Name: Smithsters Trust
  • Settlor: Acis Settlements Pty Ltd
  • Trustee: Smithsters Pty Ltd
  • Appointors: John Smith & Mary Smith
  • Named Beneficiaries: John Smith & Mary Smith

The fees for completing Identification & Verification procedures as part of these orders would be $18.00 + GST, being 2x the Individuals component for the two unique individuals in positions of ownership and control in Smithsters Pty Ltd, being John Smith & Mary Smith. This fee would be shown on the invoice for Smithsters Pty Ltd.

There would be no fee on the invoice for Smithsters Trust because the unique individuals who have positions of ownership or control, being John Smith & Mary Smith, have already been identified and verified as part of the order for Smithsters Pty Ltd. The Acis system will identify them as duplicates and re-use the previous validations (for up to 12 months).

Example 2: Company Order with Trust Shareholders

Company Order:

  • Company Name: Investment Co Pty Ltd
  • Directors: Susan Jones, Alison Long
  • Shareholder: Jones Pty Ltd ATF Jones Family Trust
    • Appointors: Susan Jones & Samuel Jones
    • Named Beneficiaries: Susan Jones & Samuel Jones
    • Trustee: Jones Pty Ltd
      • Directors: Susan Jones & Samuel Jones
      • Shareholders: Susan Jones & Samuel Jones
  • Shareholder: Long Pty Ltd ATF Long Family Trust
    • Appointor: Alison Long
    • Named Beneficiaries: Alison Long & Jacob Long
    • Trustee: Long Pty Ltd
      • Directors: Alison Long & Jacob Long
      • Shareholders: Alison Long & Jacob Long

The fees for completing Identification & Verification checks as part of these orders would be $162.00 + GST, being:

  • $18.00 + GST for 2x the Individuals component for the two unique individuals in positions of control in Investment Co Pty Ltd, being Susan Jones & Alison Long.
  • $9.00 + GST for 2x Trusts component for the two unique trusts in positions of ownership in Investment Co Pty Ltd, being Jones Family Trust & Long Family Trust.
  • $117.00 + GST for 2x Company components for the two unique companies in positions of control in Investment Co Pty Ltd, being Jones Pty Ltd & Long Pty Ltd.
  • $9.00 + GST for 1x the Individual component for the one unique individual in a position of control and ownership in Jones Pty Ltd, being Samuel Jones.
  • $9.00 + GST for 1x the Individual component for the one unique individual in a position of control and ownership in Long Pty Ltd, being Jacob Long.

This would be shown on the invoice for Investment Co Pty Ltd.

Terms and Conditions 

 To support these changes, Acis will be updating its Terms and Conditions from 1 July 2026, including provisions relating to AML/CTF compliance, reliance arrangements, client representations and verification services. The updated terms & conditions will be available on the Acis website from 1 July. A copy will also be emailed to you. 

Questions? 

Our objective is to make compliance with these reforms as simple and efficient as possible whilst maintaining the integrity of the regime.  

If you have any questions about these changes or how they will apply to your firm, please contact the Acis team. We are here to help. 

Frequently Asked Questions

What is AML/CTF?

AML/CTF stands for Anti Money Laundering and Counter Terrorism Financing.

Australia’s AML/CTF framework is governed by the AML/CTF Act and Rules and enforced by the Australian Transaction Reports and Analysis Centre (AUSTRAC).

The AML/CTF framework is designed to detect, deter, and disrupt financial crimes, including:

  • Using legitimate businesses to conceal illicitly obtained funds through money laundering.
  • Moving money to support terrorist activities.
  • Moving money to support the development or spread of weapons of mass destruction (proliferation financing).

When money laundering or terrorism financing goes undetected, it can:

  • Enable serious crime to continue, including fraud, drug trafficking and criminal exploitation;
  • Undermine public trust in the financial system and legitimate businesses;
  • Cause real harm to individuals, businesses, communities and the economy; and
  • Expose legitimate businesses to legal, financial and reputational consequences.
What is Tranche 2, is my profession captured and why does it apply to Acis?

Historically, the AML/CTF regulations captured Financial Services, Bullion, and Gambling Services (Tranche 1).

From 1 July 2026, Australia’s Tranche 2 reforms expand the regulations into industries that are recognised domestically and globally as high-risk for criminal exploitation, including:

  • Real Estate Professionals;
  • Conveyancers;
  • Dealers in Precious Metals/Stones;
  • Lawyers;
  • Accountants; and
  • Trust and Company Service Providers.

Acis offers products encompassing:

  • Company, trust, and self-managed super fund formations; and
  • Amendments resulting in changes in control or ownership.

As a result, Acis is a reporting entity for AML/CTF purposes and must comply with the AML/CTF Act and Rules.

Does this impact all Acis products?

Only products classified as a Designated Service are impacted.

A Designated Service is a service listed in section 6 of the AML/CTF Act. These are regulated because they have been identified as posing a risk for money laundering, terrorism financing, or proliferation financing.

AML/CTF impacted

  • Company incorporation.
  • Trust establishment.
  • Self-managed super fund establishment.
  • Trust deed of amendment – change of trustee, principal/appointor, and/or beneficiary.
  • SMSF deed of amendment – change of trustee, and/or member.
  • Company secretarial – director appointment, share issue/transfer.
  • Limited Recourse Borrowing Arrangements (LRBA).
  • Company share buy backs.
  • Partnership agreements, shareholders’ agreements and unitholders’ agreements.

No impact

  • Trust deed of amendment – deed upgrade, vesting deed, ratification.
  • SMSF deed of amendment – deed upgrade, vesting deed, ratification.
  • Company secretarial – company name change, company register.
  • Company constitution upgrades.
What is reliance and how am I eligible?

Many Acis clients operate in industries that will also be captured by the Tranche 2 AML/CTF reforms.

Acis may be able to rely on the customer identification and verification procedures you have already completed when:

  • You are a reporting entity and currently enrolled with AUSTRAC;
  • You have completed all required AML/CTF processes, including customer due diligence and identity verification;
  • You have identified and verified ultimate beneficial owners where required;
  • You consent to Acis relying on those verifications; and
  • You are prepared to provide evidence of compliance if requested.

Where reliance is used, Acis does not need to duplicate these procedures.

From 1 July 2026, Terms and Conditions will include a reliance arrangement, with opt in/out available per order.

What verifications can Acis add to my order?

If reliance doesn’t apply, you can add customer identification and verification procedures to your order.

Following submission, a separate verification process will be initiated through First AML.

  • Individuals: Identity verification, Politically Exposed Person (PEP) screening and sanctions screening.
  • Companies: ABN/ACN verification and sanctions screening.
  • Trusts/SMSFs: Deed verification.
Who needs to complete identification and verification?

Identification and verification must be completed for parties in positions of control or ultimate beneficial ownership.

Component Type Who Needs Identification and Verification
Individual The Individual
Company The Company Entity, Each Director, Each Beneficial Owner
Trust/SMSF The Trust/SMSF Entity, Each Trustee, Each Appointor or Controller, Each Beneficial Owner
What do verifications cost if I add them to my Acis order?

Customer identification and verification fees apply on a per-party basis.

The total cost of an order depends on the number and type of parties requiring verification.

Component Type Acis Fee (excl. GST)
Individual $9.00
Company $58.50
Trust/SMSF $4.50

Refer to the pricing examples above for how pricing applies.

Can I reuse previously completed verifications?

Yes. If a verification has been completed after 1 July 2026 and the same party appears in another order, it may be reused for up to 12 months.

What happens if I do not wish to complete verifications?

All non-designated service products remain accessible.

Designated service products require verification through:

  1. Reliance; or
  2. Adding verification to the Acis order.

Orders cannot be processed until all required verification steps have been completed.

Acis does not provide advice in relation to commercial law, taxation, duty, company law or any other matter. We do not purport to provide advice nor should you construe anything in any correspondence with us, or material provided by us, as advice of any kind.
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