AML for Accountants 2025

Introduction

As regulators across Australia and New Zealand tighten their focus on Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF) frameworks, accountants are finding themselves under increasing pressure to understand their obligations—and demonstrate their compliance.

Whether you’re in public practice, internal finance, or advisory services, AML isn’t just for banks. Accountants are often in a position to detect red flags, implement controls, and support client due diligence. That’s why Anti-Money Laundering CPD is not just relevant—it’s critical.

In this article, we’ll break down:

• The AML/CTF requirements for Australian accountants
• How AML training counts as CPD (including for CPA Australia and CA ANZ members)
• The key learning areas to focus on in 2025
• Why AML Matters for Accountants

Money laundering is a global issue—but its implications for accountants are specific and legal.

In Australia, the AML/CTF Act (2006) governs financial reporting entities under AUSTRAC, and in some cases, accountants are directly or indirectly captured under “designated services.” 

In New Zealand, the AML/CFT Act 2009 is enforced by the DIA (Department of Internal Affairs), which lists accountants explicitly among Phase 2 reporting entities when performing captured activities such as:

• Managing client funds or accounts

• Acting as a formation agent for companies or trusts

• Preparing or carrying out financial transactions on behalf of clients

Even if your practice is not a “reporting entity,” you may still be liable if:

• You work with clients involved in high-risk industries

• You help set up legal structures that may be misused

• You fail to report suspicious matters

Failure to comply can lead to:

• Regulatory fines

• Reputational damage

• Criminal liability in some jurisdictions

That’s why AML-focused CPD is no longer optional—it’s part of your ethical and professional obligations under bodies like CPA Australia, CA ANZ, and IPA.

While many CPD resources cover general AML rules, sector-specific insights are becoming increasingly valuable. For instance, if you advise fund managers, you may benefit from reading sector-specific updates like:

AML/CTF Update: Impact for the Funds Management Industry – A short course exploring compliance expectations and red flag indicators specific to funds management, an often-overlooked high-risk sector.

Does AML CPD Count Toward Your Compliance?

Yes—AML/CTF training counts as both verifiable and unverifiable CPD, depending on the format:

CPA Australia requires a minimum of 20 CPD hours per year, and as of 2024, at least 2 hours must be in ethics or risk-related areas, which includes AML.

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2025 AML Learning Priorities for Accountants (Revised)

As both AUSTRAC and New Zealand’s DIA refine enforcement strategies, accountants need to focus their AML CPD learning on five priority areas in 2025:

1. Customer Due Diligence (CDD) & Enhanced Due Diligence (EDD)

Understanding when to apply standard versus enhanced due diligence is foundational. In 2025, expect more scrutiny around verifying Ultimate Beneficial Ownership (UBO), especially for trusts, layered entities, and offshore clients. As digital identity solutions expand, accountants should also update themselves on how to verify identities remotely and securely, while meeting compliance standards.

2. Suspicious Matter Reporting (SMR)

Detecting and reporting suspicious activity remains a core AML responsibility. Accountants should learn how to identify red flags—such as inconsistent financial flows or unexplained structuring—and understand when a Suspicious Matter Report must be submitted. Maintaining thorough documentation and understanding escalation procedures within your firm is just as critical.

3. Firm-Level AML Risk Assessments

Every practice—regardless of size—should maintain an AML risk assessment register. Your 2025 CPD should revisit how to evaluate clients based on industry, geography, and transaction behavior, and how to update scoring frameworks in response to new risks. Tools like risk matrices and tiered review models can support consistent implementation.

4. Recordkeeping & Documentation

Effective AML recordkeeping means more than just box-ticking. You should understand what must be recorded, such as identity verification documents, SMR filings, and due diligence notes—and for how long (7 years in Australia, 5 years in NZ). More importantly, ensure your files are structured for external auditability, with version tracking and secure access controls.

5. Ethical Dilemmas & Escalation

Beyond legislation, AML compliance is an ethical challenge. You may need to navigate confidentiality versus public duty, or client relationships versus legal obligations. CPD in this space should help you explore real-world case studies, understand how to escalate concerns to your MLRO or supervisor, and recognize when it’s time to disengage from a high-risk client.

To deepen your understanding of these dilemmas, you may wish to explore a structured bundle on judgment and integrity:

Micro-Credential: Ethical Decision-Making – This focused CPD bundle explores how to weigh ethical complexity and document defensible decisions, a skill central to AML reporting and disengagement decisions.

Continuing AML Learning in 2025

If you're actively managing clients, teams, or compliance systems, consider enrolling in structured, verifiable CPD on AML topics.

If you want more flexibility to explore AML, ethics, tax, audit, and other key areas on your own schedule, you may prefer a self-paced subscription model.

Unlimited CPD Access – Explore Ethics, AML, and More – Ideal for accountants seeking low-cost, all-inclusive CPD with access to 1,000+ hours of accredited content, including risk and ethics modules aligned with CPA and CA ANZ guidelines.

Final Thoughts

AML obligations are not just legal checkboxes—they reflect our profession’s role as protectors of financial integrity. Whether you're a sole practitioner or part of a large firm, engaging with AML-focused CPD ensures you remain alert, ethical, and audit-ready.

Taking one hour to read, reflect, and log your understanding is a small investment with significant compliance—and reputational—returns.