Australia’s anti-money laundering laws have expanded. From 1 July 2026, the same obligations that have applied to banks and financial institutions for years now extend to professional services firms — including platform providers like Smarter SMSF that facilitate trust and company formations.
This isn’t a cause for alarm. Most of what you do today continues exactly as before. But for a specific category of documents, there is now a compliance step built into the process — and we’ve spent the last 18 months building it directly into the platform so it’s as seamless as possible.
Here’s everything you need to know.
What Has Actually Changed?
The Anti-Money Laundering and Counter-Terrorism Financing Amendment Act extended Australia’s AML/CTF framework to professional services in March 2024, with obligations commencing 1 July 2026.
The legislation captures what’s called “designated services” — specifically, services that create new legal entities or transfer control of existing ones. For Smarter SMSF, that means trust formations and company incorporations fall within scope.
As a result, Smarter SMSF is now a reporting entity under the AML/CTF Act. That means we have formal obligations to:
- Verify the identity of firms accessing designated services (Know Your Business, or KYB)
- Verify the identity of individuals associated with each designated service order (Know Your Customer, or KYC)
- Maintain records for seven years
- Report to AUSTRAC where required
Which Documents Are Affected?
This is the most important thing to understand — the vast majority of Smarter SMSF documents are completely unaffected.
AML/CTF applies to primarily to trust and company formation on the Smarter SMSF platform:
- New SMSF Establishment
- LRBA (Bare Trust) Setup
- LRBA Loan Facility Agreement
- Discretionary (Family) Trust
- Fixed Unit Trust
- Company Incorporation (including Special Purpose)
- Change of Trustee (all variations)
No change at all for:
- Pension commencements (all types)
- Binding and non-binding death benefit nominations
- Investment strategies
- Deed variations and trust deed updates
- Company constitution only orders
- In-house asset loan agreements
- All other standard SMSF administration documents
If you primarily use Smarter SMSF for pension documents, investment strategies, or deed variations, today works exactly the same as yesterday. Nothing has changed.
How Verification Works
How verification works depends entirely on which pathway your firm is on. There are two options — and the one that applies to you is determined by a single question during sign-up: does your firm have its own AUSTRAC-registered AML/CTF program?
Pathway A — Reliance Agreement (firms with their own AML program)
This pathway is designed for accounting and advisory firms that are already registered with AUSTRAC as reporting entities and maintain their own AML/CTF program.
Step 1 — One-time firm verification
Before designated services are unlocked, your firm completes a one-time verification through the Compliance Hub:
- KYB (business verification): Your entity is checked against the ASIC register and ABN records, and screened for PEP and sanctions exposure.
- KYC (principal identity): Each director and beneficial owner holding 25% or more completes a VerifiMe digital identity check — 2–5 minutes on any device, photo ID plus biometric selfie match.
Once complete, you sign a formal Reliance Agreement with Smarter SMSF under Section 40 of the AML/CTF Act. This agreement confirms that Smarter SMSF can rely on your firm’s own compliance and KYC practices for each designated service order.
Step 2 — Per-order attestation (no client action required)
When you place a designated service order, you confirm via a simple attestation that you’ve completed your own client due diligence. The document is released immediately — your client doesn’t need to do anything at the order stage.
Pathway B — Full CDD via VerifiMe (all other firms)
This is the default pathway for most Smarter SMSF members — bookkeepers, sole practitioners, mortgage brokers, SMSF trustees, and any firm without their own AUSTRAC-registered AML program.
No firm-level verification is required. There’s no Compliance Hub onboarding, no Reliance Agreement, and no separate registration step for your firm.
Per-order client verification works like this:
- You place the order as normal and enter your client’s name and email
- Your client receives a secure VerifiMe invite by email
- They complete a 2–5 minute digital identity check on their phone or computer — photo ID plus biometric selfie match
- Once confirmed at LOW or MEDIUM risk, the document is released automatically
Repeat clients: Once a client is verified, the record is cached against your account for 12 months. No re-verification and no new fee for any subsequent designated service order within that period — the document releases immediately.
About VerifiMe
We chose VerifiMe as our identity verification partner because it’s purpose-built for AUSTRAC Tranche 2 compliance in the Australian professional services sector. The platform handles:
- Government document validation
- ASIC and ABN register checks
- Biometric face matching
- PEP and sanctions screening
Importantly, Smarter SMSF never sees or stores your client’s raw identity documents. We receive a verified attestation — a pass/fail result with a risk rating — and nothing more. Your client’s actual ID remains within the VerifiMe platform, secured under AES-256 encryption with Australian data sovereignty guaranteed.
VerifiMe also gives clients a reusable verified identity wallet. If your client has already been verified by another Tranche 2 professional using VerifiMe, they can share their existing credentials with a simple two-click consent process — no repeat verification, no new fee.
What Do You Need to Do?
If you’re an existing Smarter SMSF member:
Log in to your account and go to the new Admin Console → Compliance Hub. You’ll find a guided workflow that walks you through firm verification and, if applicable, the Reliance Agreement. The whole process takes around 15 minutes.
You can continue using all non-designated service documents at any time — there’s no impact on pension documents, investment strategies, or deed variations while you complete compliance setup.
If you’re signing up for the first time:
AML/CTF compliance is built into the new member registration wizard – via the PAYG sign up page. You’ll be guided through the process during sign-up — including the single question about whether your firm has its own AML program. For most new members, the entire process from registration to first designated service order can be completed on day one.
If you manage a team subscription:
AML/CTF compliance is managed at the firm level by the account owner. Team members inherit the firm’s AML status automatically — they don’t need to complete separate verification. When a team member places a designated service order, the firm’s pathway applies in the background.
The Bottom Line
The law has changed, and we’ve been doing the work to make sure compliance is as simple as possible.
For most documents, nothing changes. For designated services — SMSF establishments, trust formations, company incorporations, and LRBA documents — there’s now a verification step that has to happen in the background, either via a client VerifiMe invite or your firm’s Reliance Agreement attestation.
If you have questions about which pathway applies to your firm, what the Reliance Agreement involves, or how VerifiMe works in practice, our team is available to help.
📞 1300 95 94 76 ✉️ team@smartersmsf.com 🔗 Book a call with our team
For full details on which documents are affected and how the compliance process works, visit smartersmsf.com/documents/aml-ctf-tranche-2/.
Smarter SMSF is a reporting entity under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth). This article provides general information only and does not constitute legal or compliance advice. For advice specific to your firm’s obligations, consult a qualified AML/CTF compliance professional or legal adviser.
