Sending Every Insolvency File to the Same Liquidator: What Tranche 2 Changed for Accountants

Sending Every Insolvency File to the Same Liquidator: What Tranche 2 Changed for Accountants

Since 1 July 2026 you are a reporting entity. So is the liquidator, administrator or trustee you refer your clients to. That is the part most practices have not worked through yet: the referral itself now sits inside two separate AML/CTF programs, and the pattern of always sending files to the same practitioner is now the exposed position rather than the safe one.

This is not a warning about doing something wrong. It is about what a documented, defensible referral process looks like now that both ends of it are regulated.

What actually makes you a reporting entity

The Anti-Money Laundering and Counter-Terrorism Financing Amendment Act 2024 (Cth) extended the regime to accountants, lawyers, real estate professionals and trust and company service providers. Obligations commenced 1 July 2026, and enrolment with AUSTRAC closed on 29 July 2026.

Being an accountant does not make you a reporting entity. Providing a designated service does. The professional designated services sit in table 6 of section 6(5B) of the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) — nine items in total. The ones that catch ordinary accounting work are:

Item	Designated service
2	Assisting in planning or executing the transfer of a body corporate or legal arrangement
3	Receiving, holding, controlling or managing money or property for a transaction
4	Assisting in organising or planning equity or debt financing
6	Assisting in planning or executing the creation or restructuring of a body corporate or legal arrangement
7	Acting as, or arranging for someone to act as, a director, secretary, trustee or partner
8	Acting as, or arranging for someone to act as, a nominee shareholder

Item 6 is the one that matters here. Restructuring a body corporate is a designated service, and that is the language a Small Business Restructuring, a deed of company arrangement or a pre-appointment restructure sits squarely inside.

The practitioner you refer to is captured too

AUSTRAC confirmed in guidance issued on 19 June 2026 that formal insolvency appointments — liquidations, voluntary administrations and receiverships — can themselves be designated services, as can informal advisory work before any appointment. Insolvency practitioners had the same 29 July 2026 enrolment deadline you did.

So the same client file is now being risk-assessed twice, by two reporting entities, against two AML/CTF programs. Where that file came from is part of what each of you has to assess.

Why the single-referrer habit is the exposed one

AUSTRAC identifies intermediary, third-party and referral arrangements as a delivery channel risk factor — particularly where instructions arrive through someone other than the customer and there is minimal direct contact with the customer themselves. That describes a large share of insolvency referrals: the accountant briefs the practitioner, and the practitioner may have limited contact with the director until an appointment is close.

That does not make a referral suspicious. It makes the referral channel something both ends now have to risk-rate and document, rather than treat as a professional courtesy.

Concentration is the part worth thinking about. A practice that routes every insolvency file to one practitioner, and a practitioner who receives a disproportionate share of files from one referrer, together form a closed channel with little independent verification in it. It is also the shape that ASIC and the ATO already watch for in illegal phoenix activity. None of that is an allegation against anyone — it is simply a pattern that now attracts a question, and the practice that can answer it in writing is in a much better position than the one relying on "we have always used them".

You cannot lean on their KYC informally

The common assumption is that if the liquidator has verified the client, that covers the file. It does not, unless it is documented properly.

Reliance on another reporting entity's customer identification is governed by section 37A of the AML/CTF Act. It requires a written customer due diligence arrangement, entered into on reasonable grounds that the other party has appropriate systems and controls meeting the requirements in Chapter 7 of the AML/CTF Rules. A senior manager has to approve it. Informal reliance on a referrer's or a practitioner's KYC gives you no safe harbour at all.

If your practice already had arrangements in place before 1 July 2026, they need reviewing against the amended Act and Rules — pre-existing arrangements do not automatically carry over.

What a defensible referral process looks like

The answer is not to stop referring. It is to be able to show why this client went to this practitioner.

Instead of	Do this
One practitioner for every file	A panel of practitioners, matched to the matter — SBR, liquidation, bankruptcy and turnaround are different skill sets
A phone call and a name	A short file note recording why that practitioner suited that client
Assuming their KYC covers you	A written section 37A CDD arrangement, or run your own customer due diligence
An undocumented standing relationship	A referral channel you have risk-rated, like any other delivery channel

A panel takes more work than a speed dial. It is also the version you can hand to AUSTRAC, to your professional body, or to a court, and have it hold up.

Where I fit

I'm not a liquidator, trustee or administrator, and I don't act for creditors. I work for the client and I coordinate — reading the position from the director's side, working out which of the real options fits the numbers, and matching the file to an appropriate practitioner rather than the same one every time. For an accountant, that means the referral decision is made and documented on its merits, and your client stays your client. In 38 years I've never once heard someone say they acted too early.

If you have a client file you would rather not send to the usual name, book a phone or video time at resolvency.com.au/book or call 0457 099 099.

General information only — not financial, legal or tax advice, and not AML/CTF compliance advice. Your obligations depend on the designated services your practice actually provides. Confirm your position with your own adviser and against current AUSTRAC guidance before you act.

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Related service: Accountant & Referral Partner Support — see how I can help.