By:
Chris Batten
Director, Macquarie Group Services
From 1 July 2026, the AML/CTF regime will extend to accounting practices that provide designated services, most commonly setting up a company, managing company officeholders, establishing a trust or SMSF, or acting as registered office. For such firms, identifying and working with a trusted provider will be paramount to ensuring compliance with the new regime, and in optimising efficiency across workflows.
In the new regulatory climate, retention of manual processes will hurt accounting firms on numerous fronts, including onboarding, re-keying, and due diligence. Repeatedly collecting and verifying the identity of the same individuals behind an entity is not simply a time-suck; it is another chance for error, an additional item for reconciliation during audit.
As Macquarie Group Services director Christopher Batten puts it, the risk of non-compliance “does not look like one big failure to do something, but rather all the little things that add up”. This could include, he says, a missed review, an unverified party, or a record you can't produce on request. “Manual processes rely on someone being dedicated to staying on top of all of that, and for most firms, that’s not realistic.”
Those that fear the looming compliance obligations, and have concerns for slower onboarding times and impacted client experiences, are those still relying on manual processes. The friction, Batten says, isn’t in the verification itself, but in everything around it. “Modern identity verification databases are fast; what takes time is re-keying data, chasing documents, and repeating checks you've already run. When you remove the duplication and rigorous compliance, you also remove any delays in onboarding times,” he says.
“The biggest single way a firm can maintain a smooth onboarding is by using a system that has been designed with this in mind. A big part of this is to verify-once, and reuse-everywhere. A family-office principal who sits on five trusts and three companies should be verified one time, not eight. When an existing verification is recognised automatically wherever that person next appears, be it on another client or on a document order, onboarding the ninth entity takes minutes rather than requiring a fresh round of checks.”
Leaning on trusted providers to ensure both rigorous compliance and a frictionless onboarding journey for clients matters, Batten says, because friction usually lives in the transfer between systems.
“The biggest single way a firm can maintain a smooth onboarding is by using a system that has been designed with this in mind. A big part of this is to verify-once, and reuse-everywhere. A family-office principal who sits on five trusts and three companies should be verified one time, not eight. When an existing verification is recognised automatically wherever that person next appears, be it on another client or on a document order, onboarding the ninth entity takes minutes rather than requiring a fresh round of checks.”
Leaning on trusted providers to ensure both rigorous compliance and a frictionless onboarding journey for clients matters, Batten says, because friction usually lives in the transfer between systems.
“If verification, screening, entity formation and ongoing monitoring sit on one platform with one client record, there is no transfer from one system to another. The client experiences a single, smooth onboarding. The right partner is the one that has already removed the handoffs, not one that adds another system the practice has to bridge,” he notes.
In determining the right partner for those helping establish trusts and companies, the importance of integration cannot be overstated.
What will be so taxing about the regime is not a single check, but the duplication, Batten notes, from the same data captured twice to having two logins or audit trails to reconcile. “Technology, specifically an integrated system, that removes the duplication is what turns Tranche 2 from a margin problem into something more manageable,” he says.
Macquarie Group Services, he outlines, has established companies and trusts for accounting practices for over 25 years, and what the provider hears over and over is that what firms want isn't more software, it’s a more streamlined experience. This means fewer moving parts, integration across all stages of the process, and a partner who already understands how trusts and companies are actually established.
“We start from a position most providers can't: we already establish the companies, trusts and SMSFs that accountants register for clients,” Batten says, adding that Macquarie AML extends that into a single platform, whereby compliance and document-ordering share one client record.
Establishing trusts and companies has traditionally involved multiple systems, touchpoints and manual verification steps. For those using Macquarie Group Services, the workflow closes the loop.
As Batten explains: “An accountant onboards the client, verifications run and screenings clear, then those clients slot right into the trust, company and SMSF deed process. When the accountant then orders the trust deed or company, the cleared individuals appear as fillable parties, pre-populated, with no re-typing.” When the order completes, he says, the new entity can be automatically onboarded back into the platform as a client, with its verified directors, trustees or beneficial owners already in place.
In this system, there is no second verification fee, and no second data entry – just one audit trail across the entire engagement.
Around this core, he continued, Macquarie Group Services has established a system to handle the balance of obligations for practitioners and their businesses. Firms are supported in the creation of a compliant AML/CTF program and risk assessment that is proportionate to their practice, while AUSTRAC reporting escalation workflows are built in, with deadlines tracked and tipping-off protections enforced. Moreover, the seven-year record retention is applied automatically, and role-based staff training is also contained in the system.
For firms looking to streamline trust and company establishment workflows, whilst also embedding robust compliance frameworks from day one, Batten says that best practice means not treating compliance and entity establishment as two separate jobs. They’re inherently linked, he notes.
For accountants, AML obligations are triggered by the very act of setting up a company or trust, he advises, “so the right moment to verify a client is at the point you're establishing their structure rather than in a separate exercise bolted on afterwards”.
Practically, this requires: having one client record, in which identity is captured and verified once, structured properly, and reused everywhere that person appears; embedding compliance at the formation of an entity, whereby verified individuals are already in place as its directors, trustees or beneficial owners, and the program, risk assessment and audit trail come from the same workflow, rather than an external one; having a program that is proportionate to the practice (“the lightest framework that fully meets the requirement”, Batten says); and having one audit trail, with everything in one place against one engagement.
When implemented from day one, Batten says, “compliance stops being a tax on every new client, and becomes a byproduct of work the practice was already doing”.
Firms should already be on this journey, but for those yet to start, “the second-best time is today”. To those practices, Batten suggests starting now, and with scope.
Firstly, confirm whether your practice provides designated services, and from there, “the building blocks are well defined: enrol as a reporting entity, put an AML/CTF program and ML/TF risk assessment in place, appoint a compliance officer, stand up your customer due diligence and ongoing monitoring, train your staff, and make sure records and reporting are handled with deadlines tracked”. Such steps can seem overwhelming, Batten says, if one doesn’t have access to a well-structured system or platform. However, he adds, it doesn’t need to be.
Secondly, firms would be mistaken to treat these obligations as a one-off project to finish by a deadline. The question for Tranche 2 entities isn't only ‘are we compliant by July’, but ‘is our workflow built to do this efficiently every day after’. Here, a firm’s choice of provider and platform “becomes more important than ever”, and now is the moment to reassess the platforms being relied upon for KYC, AML and entity establishment.
“If KYC, AML and entity establishment live in separate systems, you'll be paying the price not just in fees, but time and lost efficiency,” Batten says. “Getting yourself set up with the right provider is paramount so you don’t lock your practice into a system and process that doesn’t work as hard for you as it could.”
Chris Batten
Director, Macquarie Group Services
Australia's most trusted tax, trusts & superannuation provider for more than 25 years.
For more than 25 years, Macquarie Group Services has been the trusted partner of accountants, lawyers and financial planners across Australia — delivering cutting-edge precedent documents, expert tax consulting, tribunal representation and the most comprehensive professional education platform in the country.
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