Tranche 2 of Australia’s AML/CTF reforms took effect on 1 July 2026. Accounting practices that provide designated services, such as assisting with company or trust formation, or managing client money or assets where this forms part of a designated service, are now reporting entities under the AML/CTF Act. For many practices, that question is already settled. Enrolment with AUSTRAC is done, a compliance officer has been appointed, and the firm has worked out which engagements actually trigger obligations.
What is left is a more practical decision: which AML screening tool actually fits how the practice works. This guide sets the compliance question aside (NameScan’s guide to what AUSTRAC expects from accountants under Tranche 2 covers that in detail) and focuses on the buying decision. It covers what AML screening software needs to do for an accounting practice, what to check before committing to a vendor, the mistakes practices commonly make, and why the way accounting practices actually use screening, occasionally and tied to specific engagements rather than continuously, should shape the pricing model you choose.
What AML screening software needs to do for an accounting practice
For a designated service, customer due diligence requires verifying the client’s identity, identifying beneficial owners of any company or trust involved, and screening the client and those beneficial owners against sanctions lists, politically exposed person (PEP) databases and adverse media sources before the designated service is provided. Screening continues afterwards too. A new beneficial owner, a change in ownership structure, or new adverse media about an existing client should feed back into the practice’s ongoing risk assessment.
Software chosen for this purpose has one job: make that step fast, defensible, and properly recorded. It should not turn client onboarding into a technology project of its own, and it should not require the practice to run three separate subscriptions to cover sanctions, PEP, and adverse media checks.
A practical checklist for evaluating AML screening software
- Combined coverage. One search or report that returns sanctions, PEP, and adverse media results together, rather than three separate products or logins.
- Beneficial ownership support. The ability to screen beneficial owners identified during a company or trust formation engagement in the same way as the instructing client, not as a separate manual step.
- A clear match review workflow. A way to review a potential match, record the decision, and note why a result was cleared or escalated. A PEP or sanctions match is a risk factor to assess, not proof of wrongdoing, and the software should support that judgement rather than force an automatic outcome.
- Audit-ready records. Exportable reports and a record of who screened whom, when, and against what source, since AUSTRAC requires records to be made and kept for at least seven years.
- Pricing that follows designated-service volume. A cost structure that scales with the number of checks actually performed rather than with the practice’s total client list.
- Straightforward onboarding. Something a practice manager can set up without a dedicated IT project, since most accounting practices do not run a compliance technology team.
- Transparent data sourcing. Ask any vendor how often sanctions, PEP, and adverse media sources are updated and how false positives are handled. Coverage and accuracy vary across the market, and this materially affects how much review work your staff end up doing.
Why usage pattern matters more than most software comparisons admit
Designated services are a subset of an accounting practice’s total engagements, not the whole client base. A firm might have hundreds of tax and bookkeeping clients and only a handful of company formation or trust matters in a given month. AUSTRAC’s customer due diligence obligations apply to the engagements that are designated services, not automatically to every client relationship. For most accounting practices, that makes realistic screening volume occasional and tied to specific engagement types, rather than continuous.
A subscription priced for continuous monitoring of a large client population can leave a practice paying for capacity it rarely uses. A pay-per-check model, where cost tracks the number of checks actually performed, tends to fit this occasional pattern more naturally, because the bill moves with designated-service volume rather than with total client numbers or firm size. This is a genuine, structural reason PAYG pricing suits many accounting practices, not just a general preference for lower upfront cost.
That is not a universal rule. A practice with a genuinely high and steady volume of designated-service work, for example one that specialises in company formations or trust administration, may find a subscription cheaper once volume is high and predictable enough. The only way to know is to model both options against the practice’s actual expected designated-service volume, not its total client count. NameScan’s PAYG vs subscription cost comparison walks through that modelling in more detail and is worth working through before committing either way.
Common mistakes accounting practices make when choosing screening software
- Sizing the tool to the whole client base. Obligation attaches to designated services, not to the professional title of accountant. Budgeting for screening capacity across every client, including tax-only clients, usually overstates what the practice actually needs.
- Treating a match as a decision rather than a starting point. A PEP or sanctions match means a name has matched a list entry, not that the client has done anything wrong. Software that does not help staff document why a match was cleared or escalated leaves a weaker record than one that does.
- Assuming the software replaces the AML/CTF program. Screening is one control inside a documented AML/CTF program. It does not substitute for a risk assessment, written policies, staff training, or suspicious matter reporting where required.
- Choosing on price alone. The lowest per-check rate is not a saving if match quality is poor and staff spend hours chasing false positives, or if the vendor cannot produce the records AUSTRAC would expect to see in a review.
Questions worth asking before you commit
- Does one search return sanctions, PEP and adverse media results together, or are these separate products?
- Can a beneficial owner identified during a company or trust formation engagement be screened the same way as the instructing client?
- How are potential matches reviewed, and can the outcome and reasoning be exported or retained as part of the practice’s records?
- Is pricing based on checks performed, a fixed subscription, or a hybrid, and does that match the practice’s actual designated-service volume rather than its total client list?
- How often are sanctions, PEP and adverse media sources updated, and what does the vendor disclose about coverage?
How screening software fits into the practice’s broader AML/CTF program
Screening software supports one part of the AML/CTF program AUSTRAC requires from designated-service providers: customer due diligence. The broader program also needs a documented risk assessment, policies and controls proportionate to the practice’s size and complexity, an appointed AML/CTF compliance officer, staff training, and reporting of suspicious matters where the relevant threshold is met. A good screening tool makes the due diligence part of that program faster and better documented. It is not a substitute for the rest of it.
Accounting practices are not the only newly regulated profession working through this. NameScan’s guide to Tranche 2 for lawyers and legal practices covers how the same reforms apply to a related profession facing a similar set of decisions.
Frequently asked questions (FAQs)
Does an accounting practice need dedicated screening software, or can checks be done manually?
Manual checks against sanctions and PEP lists are possible in principle, but they become time-consuming and harder to document consistently once a practice handles more than an occasional designated-service engagement. Software formalises the check and creates the kind of record AUSTRAC would expect to see if it reviewed the practice’s due diligence.
Does AML screening software on its own satisfy Tranche 2 obligations?
No. Screening supports the customer due diligence element of a firm’s AML/CTF program, but the program also needs a documented risk assessment, policies, an appointed compliance officer, staff training and, where relevant, suspicious matter reporting. Buying screening software is one step, not the whole program.
Is PAYG or subscription pricing better for an accounting practice?
It depends on how much designated-service work the practice actually does, not on its overall size. Practices with occasional designated-service engagements often find pay-per-check pricing a closer fit, while practices with high, steady designated-service volume may find a subscription more cost-effective. NameScan’s PAYG vs subscription cost comparison sets out how to model both.
Next step
If your practice has already worked out which engagements are designated services, the next practical step is testing a screening workflow against a real client or beneficial owner, rather than continuing to evaluate features on paper. NameScan’s PEP, sanctions, and adverse media screening is built as a pay-per-check service, which suits the occasional, engagement-based screening pattern most accounting practices actually have. This guide is built around small to mid-sized accounting practices; if yours is a large, multi-office firm with continuous, high-volume screening needs, NameScan’s sister company MemberCheck, also part of the Nexiant group, is built for that enterprise tier.
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