From 1 July 2026, Australia expanded its Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) regime to include a much broader range of professional services.

The reforms bring certain services provided by accountants, lawyers, conveyancers, real estate professionals, trust and company service providers, and dealers in precious metals and stones within Australia's AML/CTF framework.

For SMSF trustees, this does not mean that your SMSF itself suddenly becomes an AUSTRAC-regulated entity simply because it is an SMSF.

What it does mean is that when you establish or make certain changes to your SMSF, you may notice additional identification checks, questions and verification requirements from the professionals assisting you.

At SMSFai, our objective is to make this process as straightforward as possible while meeting the regulatory requirements that apply to the services we provide.

Why have the AML/CTF rules changed?

Money laundering involves disguising the proceeds of crime so that illegally obtained money or assets appear legitimate. Counter-terrorism financing laws are designed to identify and prevent funds from being used to support terrorism and other serious financial crime.

Australia's AML/CTF framework has historically focused heavily on financial institutions and other financial services businesses.

The expanded regime now captures certain designated services commonly provided by professional service businesses.

From 1 July 2026, newly regulated businesses providing designated services are required to meet obligations that can include:

• having an appropriate AML/CTF program;

• undertaking customer due diligence;

• identifying and managing money laundering and terrorism financing risks;

• reporting certain transactions and suspicious matters to AUSTRAC; and

• maintaining appropriate records.

The important point for SMSF trustees is that these obligations generally sit with the professional providing the designated service – not with you simply because you are an SMSF trustee.

How can the changes affect an SMSF?

The AML/CTF requirements can become relevant when particular professional services are provided in connection with an SMSF.

Examples may include assisting with:

Establishing a new SMSF

Identity and customer due diligence checks may need to be completed before certain establishment services can be provided.

Establishing a corporate trustee

Where a company is being established to act as trustee of an SMSF, additional AML/CTF requirements may apply to the professional providing that service.

Changing SMSF trustees

Adding or removing an individual trustee may trigger customer due diligence requirements.

Changing directors or shareholders of a corporate trustee

Changes to the directors or shareholders of an SMSF's corporate trustee may also involve designated services and additional verification.

The exact requirements depend on the service being provided and the circumstances surrounding the transaction.

What information could SMSFai ask you to provide?

You may already be familiar with proving your identity when opening a bank account, establishing an investment account or dealing with a financial adviser.

AML/CTF customer due diligence extends this concept.

Depending on the service and the level of risk involved, we may need information or documentation to establish matters such as:

• your full legal identity;

• your date of birth and residential address;

• the identity of other trustees, directors or relevant individuals;

• the ownership and control of a company or other entity;

• the purpose and intended nature of a transaction;

• the source of funds or source of wealth in appropriate circumstances; and

• other information required to understand the customer and transaction.

We may also need to conduct checks relating to politically exposed persons (PEPs), sanctions and other relevant risk indicators.

These checks are not an accusation or indication that a client has done anything wrong. They form part of the risk-based customer due diligence obligations applying to regulated businesses.

What is a Politically Exposed Person?

A Politically Exposed Person, commonly called a PEP, is someone who holds, or has held, a prominent public position or function.

Certain family members and close associates can also be relevant.

PEPs can present an increased money-laundering risk because of the nature and influence associated with their position. This does not mean a PEP has done anything wrong.

It simply means additional due diligence and monitoring may be appropriate.

What Does This Mean for Your SMSF?

For most trustees, the practical difference will be relatively simple:

You may be asked more questions before we can commence certain work.

For example, if you ask SMSFai to establish an SMSF or corporate trustee, we may need to complete required customer due diligence before proceeding.

If we request identification or supporting information, providing it promptly will help us complete the process efficiently.

There may also be circumstances where additional information is required because a transaction is unusual, particularly complex or carries a higher AML/CTF risk.

What about the source of my SMSF money?

In some circumstances, a regulated professional may need to understand where money involved in a transaction has come from.

This can involve establishing the source of funds or, where appropriate, understanding a person's broader source of wealth.

For an SMSF, funds might originate from sources such as:

• superannuation rollovers;

• employer or personal contributions;

• investment income;

• proceeds from the sale of investments; or

• other legitimate sources.

The level of information required will depend on the circumstances and the AML/CTF risk assessment associated with the service.

Will this change what an SMSF can invest in?

No.

The AML/CTF reforms do not, by themselves, change the investment rules applying to SMSFs.

They do not introduce a new prohibition on an SMSF investing in assets such as:

• listed shares;

• managed investments;

• property;

• cash and term deposits;

• cryptocurrency and digital assets;

• gold, silver and other precious metals; or

• other investments permitted under Australia's superannuation laws.

Trustees must still comply with the existing superannuation, tax and investment rules applicable to SMSFs.

AML/CTF compliance is a separate regulatory issue.

Does this change my SMSF's annual administration or audit?

The reforms do not change the fundamental annual compliance obligations of an SMSF.

Trustees remain responsible for ensuring the fund complies with its existing obligations, including maintaining appropriate records, preparing financial statements, arranging the annual independent SMSF audit and lodging the SMSF annual return.

The main AML/CTF impact arises when a professional provides a service that is specifically captured as a designated service under the legislation.

Will establishing an SMSF take longer?

Potentially.

Some identification and due diligence processes must occur before particular services can be provided.

In straightforward cases, this should simply become another part of the onboarding process.

Where additional checks or documents are required, the process may take longer.

The best way to minimize delays is to provide requested identification and supporting documentation promptly and ensure the information supplied is complete and accurate.

Privacy and protecting your information

We recognize that AML/CTF compliance can require clients to provide sensitive personal information.

SMSFai takes the protection of client information seriously. Information collected for identification, verification, compliance and administration purposes is handled in accordance with applicable privacy, security and record-keeping requirements.

The key message for SMSF trustees

Australia's AML/CTF framework has changed, but for most SMSF trustees there is no reason for concern.

The important things to remember are:

Your SMSF is not automatically subject to the AML/CTF regime simply because it is an SMSF.

Instead, certain professionals assisting you may have AML/CTF obligations when providing particular services.

You may be asked for more information.

Identification, ownership, source-of-funds and other questions may now form part of providing certain services.

The checks may need to happen before work begins.

This can mean completing identification and customer due diligence earlier in the SMSF establishment or change process.

It does not change what your SMSF can invest in.

The existing superannuation and investment rules continue to apply.

Being asked questions does not mean you are suspected of wrongdoing.

Customer due diligence is now a normal part of providing many regulated professional services.

At SMSFai, our focus remains the same: making establishing and running an SMSF as simple as possible while ensuring the services we provide meet Australia's regulatory and compliance requirements.