By Justin Amos, Co-Founder & CEO, iDeed Pty Ltd
The views expressed in this article are those of the author and reflect our interpretation of AUSTRAC’s published guidance and the AML/CTF Act as at August 2026. This article is general in nature and does not constitute legal advice. If you have questions about how the reforms apply to your specific practice, get in touch at ideedworks.com.au.
Part 1 of the iDeed post-deadline series
Something remarkable happened on 1 July 2026.
Across legal practices, accounting firms, conveyancing businesses and real estate agencies - multiple professions, each with their own client structures, their own complexity and their own compliance challenges - nearly half of Australia’s newly regulated businesses enrolled with AUSTRAC.
That is an extraordinary collective response to a major regulatory change. Tens of thousands of businesses recognised their obligations, stepped up and took the first formal step into Australia’s AML/CTF framework.
It deserves to be acknowledged.
But enrolment is exactly that - a first step. The administrative entry point into a framework that asks considerably more of you than a 30 minute online form.
And now that the deadline has passed, there are some questions worth sitting with honestly.
Six questions worth asking yourself
Tap each question below to reveal the honest answer most firms are quietly grappling with.
1. Have you done any yet?
Not enrolled - done. A CDD verification. An actual customer due diligence process on a real client. Have you gone through the steps, collected the documents, made the determination and produced an audit-ready file?
If the answer is no - you are enrolled but not yet operational. That is a gap worth closing urgently.
2. How long did it take you?
If you have done one - how long did it actually take? Not the estimate from the software vendor. The real time. The back and forth. The chasing. The questions you weren't sure how to answer. The structure you weren't sure how to unwrap.
For most firms doing this for the first time, the honest answer is considerably longer than expected.
3. Did your customer have a good experience - or were they delayed getting your services?
This is the question most firms haven't thought to ask. Your client's Director, UBO or Authorised Person received a verification request. How did that feel for them? Did it look professional and trustworthy? Or did it look like a scam? Did they understand what was being asked and why? Did they complete it quickly - or did the process drag, delaying the moment you could start billing?
The CDD process is a client touchpoint. It reflects on your firm whether you designed it that way or not.
4. Do you think your risk assessment went well - and will it stand up to scrutiny?
Did you correctly identify all the parties who needed to be verified? Did you determine the right risk rating for the client? If there was a trust structure involved - did you read the deed, map the ownership and reach the correct UBO determination? Or did the software run a percentage calculation and move on?
These are not trick questions. They are the questions AUSTRAC will ask when they review your files.
5. How much did it cost you?
Not the software licence. The real cost. The staff time. The hours your junior accountant or legal clerk spent on compliance instead of billable work. The senior partner time spent supervising or fixing. The delay to getting the new client to billable status.
Most firms haven't added this up yet. When they do, the number is often surprising.
6. Are you looking forward to doing another one?
This is the honest one.
After everything - the time, the uncertainty, the client friction, the cost - are you looking forward to the next verification landing on your desk? Are you confident it will go smoothly? Are you comfortable that your process is right, your determinations are defensible and your team knows what to do?
Or does the prospect of the next one feel like more of the same?
What the numbers tell us
As of 30 July 2026, AUSTRAC’s own data shows nearly half of the estimated 80,000 firms in scope have enrolled. The breakdown across professions is telling:
| Sector | Firms enrolled |
|---|---|
| Real estate | 17,460 |
| Accounting and professional services | 13,010 |
| Lawyers | 6,360 |
| Conveyancers | 1,580 |
| Precious metals dealers | 250 |
Nearly 40,000 businesses have not yet enrolled - and are already operating as reporting entities without meeting their legal obligations.
But here is the important point. Whether you have enrolled and are operational, enrolled and not yet doing anything, or not yet enrolled at all - from AUSTRAC’s perspective the obligation is the same.
Enrolment does not reduce your exposure if your program is not working. The question is not whether you have enrolled. It is whether you are genuinely compliant.
The good news
If your honest answers to those six questions left you uncomfortable - you are not alone. Most firms across every profession are in exactly the same position. The framework is new, the complexity is real and nobody expected it to be straightforward.
The good news is it is not too late to get this right.
iDeed exists for exactly this moment. We are an Australian SaaS platform and specialist compliance team - built for the work that professional services firms are now discovering is harder, more time consuming and more consequential than the software vendors implied.
- We do the verifications
- We read the deeds
- We determine the UBOs
- We handle the complex structures
- We deliver a professional, secure experience to your clients’ customers
- We get you to billable status faster than doing it yourself
Credits don’t expire - you only pay for completed verifications, whenever you need them. No annual fees. No idle licence costs. No headcount required.
And to answer the question in the title - when iDeed is handling your compliance, the answer to “are you looking forward to doing another one?” is yes.
Because you won’t be doing it. We will.
Book a 15 minute call at ideedworks.com.au - no pressure, just a straight conversation about where you are and what getting properly set up looks like for your firm.
Next week: what your compliance is actually costing your margin - and the numbers most firms haven’t calculated yet.
Justin Amos is Co-Founder and CEO of iDeed Pty Ltd, operators of ARCaml, an AML/CTF compliance platform built for Australian designated service providers. ideedworks.com.au
The views expressed in this article are those of the author and reflect our interpretation of AUSTRAC’s published guidance and the AML/CTF Act as at August 2026. This article is general in nature and does not constitute legal advice. If you have questions about how the reforms apply to your specific practice, get in touch at ideedworks.com.au.
Explore the full Beyond the Checkbox series.
Justin Amos
Co-Founder & CEO, iDeed Pty Ltd
Justin is Co-Founder and CEO of iDeed, operators of ARCaml - an AML/CTF compliance platform built for Australian designated service providers.
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