Insolvency practitioners who do this work
Each of these is a designated service. If your firm provides even one, AML/CTF obligations apply. See all nine
Trustees in bankruptcy: AUSTRAC says items 1 to 4 and 6 don't apply when you act in relation to an estate rather than for a specific person.
- Sell company property or shares
- Control company funds in a winding up
- Arrange funding during an administration
- Implement a DOCA share transfer
Five obligations, and where Chekbox fits
These apply from the day your firm provides a designated service. Whether it does is your firm's decision, and AUSTRAC's "check if you'll be regulated" tool can help.
Enrol with AUSTRAC
Within 28 days of first providing a designated service. Update your details within 14 days of any change.
Chekbox is itself AUSTRAC enrolled and registered. Book a consult to talk through what enrolment involves.
Run an AML/CTF program
A written risk assessment, plus the policies and controls that manage those risks. Senior management approves it and a compliance officer oversees it. In a small firm, one person can hold all three roles.
Chekbox runs and records the client checks your program sets out, and can verify your own staff when they join.
Know your client
Verify who your client is before you act, keep monitoring through the relationship, and apply enhanced checks when the risk is high.
Biometric identity checks, beneficial ownership checks and sanctions screening, with every result saved to the client's file.
Report to AUSTRAC
Suspicious matters within 3 business days, or 24 hours for terrorism financing. Cash transactions of A$10,000 or more within 10 business days. Plus an annual compliance report.
Every check is logged with who, when and the result: the evidence behind each report.
Keep records for 7 years
Your program, client checks, transactions and staff training, kept accurate and complete.
Checks, signatures and key document actions are recorded in a tamper-proof audit trail kept for 7 years. Each document's audit trail downloads as a PDF.
The nine services that bring AML/CTF obligations
Obligations come from the work you do, not your job title. If your firm provides even one of these designated services, they apply. Whether it does is your firm's decision.
Transactions
Work on a client's deal, sale or financing- Property dealsHelping a client plan or carry out the sale, purchase or transfer of real estate.For example: A liquidator selling company-owned property for the company.
- Selling a business or entityHelping a client plan or carry out the sale, purchase or transfer of a company, trust or other legal arrangement.For example: A receiver selling a company's shares in a subsidiary.
- Handling client moneyReceiving, holding or managing a client's money or property as part of a transaction.For example: A liquidator actively controlling company funds in a winding up.
- Raising financeHelping organise equity or debt financing for a company, trust or other legal arrangement.For example: An administrator arranging short-term funding for the company.
Structures
Setting up and changing companies and trusts- Setting up and restructuringHelping create or restructure a company, trust or other legal arrangement.For example: An administrator implementing a DOCA share transfer.
- Shelf companiesSelling or transferring a shelf company.For example: An adviser transferring a shelf company in a restructuring.
Roles and addresses
Acting for a client or lending your address- Acting in a positionActing, or arranging for someone to act, in certain positions such as director, secretary, partner or trustee.For example: Acting as a director or secretary on behalf of a nominator.
- Nominee shareholderActing, or arranging for someone to act, as a nominee shareholder of a company or other legal arrangement.Note: AUSTRAC says this is unlikely to apply to most insolvency practitioners.
- Registered officeProviding a registered office or principal place of business address.For example: Providing your office address to a company as a commercial service.
Not sure if your work is covered? AUSTRAC's "check if you'll be regulated" tool can help. A court appointment alone doesn't put you outside these services: the court order exception applies only where the order itself requires the activity. These services apply when they have a geographical link to Australia.
Schedule a consultOne login for the whole client file
A new appointment, start to finish.
- 1Verify the companyEntity and beneficial ownership checks confirm who owns and controls the company under appointment.
- 2Verify the people behind itDirectors and beneficial owners can each be sent their own identity check link.
- 3Run your searchesRun title and PPSR searches without leaving Chekbox, where your plan includes them.
- 4Send for signingSend sale contracts and other documents for signing, with an identity check on the signer.
- 5Keep the recordChecks, signatures and key document actions are logged and kept for 7 years.
Verify the people properly
People photograph their ID and take a selfie on their phone. Biometric facial matching, liveness detection and document authenticity checks do the rest. No client account needed.
See who controls the entity
Entity and beneficial ownership checks confirm who controls a company or trust, not just who signs for it.
Title and PPSR searches, built in
Run title and PPSR searches without leaving Chekbox, where your plan includes them. Each search is kept with its result and cost.
Key actions logged
The Activity Log shows what happened across the firm and who did it. Filter it by staff member, client or date range.
Signing that follows your process
Signing in order or any order, witnesses invited after their signatory signs, an optional identity check on the signer, and reminders before the deadline.
Certify true copies
Qualified staff certify documents with a stamp showing their name, qualification, licence number and date. Stamp every page in one step, and re-certifying updates every stamp's date at once.
What an ID document check alone leaves out
A government document check confirms an ID number exists. Here is what else Chekbox covers, in the same platform.
| What you get | ID document check on its own | Chekbox |
|---|---|---|
| Checks the ID details against government records | ||
| Matches the person to the photo on their ID* | ||
| Confirms the person is physically present (liveness)* | ||
| Certifies documents as true copies | ||
| Title and PPSR searches in the same file | ||
| Identity-verified e-signing | ||
| Entity and beneficial ownership checks | ||
| Logs key actions with who did it and when |
*Included in biometric checks, from $10 per check. The checks and searches your firm can use depend on its plan and industry.
Clear prices, recorded against each File
Every plan includes unlimited e-signing. Identity checks are charged per check, and most plans include a set number of checks. There's no lock-in contract, and plans are billed monthly.
Up and running in three steps
- 1Book a demo or start a free trialSee the platform with your own workflow in mind.
- 2Choose a plan and get verifiedWhen you subscribe, Chekbox checks your ABN, directors and owners, and a person reviews the application.
- 3Send your first client checkYour client gets a link, verifies on their phone, and the result lands in their file.
AML/CTF for insolvency practitioners
Can't find your answer? See all FAQs or schedule a consult.
Do liquidators have to comply with AML/CTF laws?
They can. What matters is what you do, not your appointment title. AUSTRAC's guidance says a designated service is more likely when you help carry out a transaction or create or restructure a company or legal arrangement, such as selling assets, controlling company funds or implementing a DOCA. Your firm makes that call.
Who is the client in an insolvency appointment?
Usually the company under appointment, even though you are a separate legal person. Creditors and shareholders don't become clients just because they benefit. Where the client isn't an individual, its beneficial ownership and control need to be established.
When do the obligations start?
Appointment alone doesn't trigger them. They start when you begin taking steps such as managing a sale, taking part in financing or restructuring, handling sale proceeds, or trading and making payments. Initial customer due diligence should be completed before you provide the service.
Does a court appointment mean we're exempt?
Not by itself. Some services exclude activities carried out under a court or tribunal order, but only where the order itself requires or gives effect to the activity, not just because you were appointed by the court or hold general powers.
What about trustees in bankruptcy?
Where you act in relation to an estate rather than for a specific person, items 1 to 4 and 6 don't apply. Item 5, selling or transferring a shelf company, may still apply in limited cases.
Do the obligations apply if my client lives overseas?
They can. What matters is whether the service has a geographical link to Australia. AUSTRAC's geographical link guidance explains how this works.
When was the AUSTRAC enrolment deadline?
For firms already providing a designated service when Tranche 2 began, enrolment was due by 29 July 2026. A firm that starts providing one later has 28 days from that date.
What does an AML/CTF program need to include?
A risk assessment covering money laundering, terrorism financing and proliferation financing, plus the policies and controls that manage those risks. Senior management approves it, a compliance officer oversees it, and it is independently evaluated at least every three years.
What happens if we don't comply?
AUSTRAC is the regulator and can take enforcement action against businesses that do not meet their obligations.
How does Chekbox verify a director or owner?
They get an email link from your firm, with your logo on it. For a biometric check, they photograph their ID and take a selfie on their phone. The result is saved in Chekbox and the cost is added to the File as a disbursement. You can also add an AML credit check, which they consent to on the same page.
How much does a check cost?
Identity checks start at $7 per check and biometric checks with a liveness scan start at $10, both AUD plus GST. Every plan includes unlimited e-signing.
Who in our firm can see an appointment's documents?
Admins see every document. Other staff see the documents they created and the documents in Files they have been given access to. Only Professional and Admin logins can sign or certify documents.
How do we get started?
Book a demo or start a free trial. When you choose a plan, Chekbox verifies your firm: your ABN, and the identity of your directors and owners. Then send your first check.
Tranche 2 began on 1 July 2026.
Get your firm's client checks in order, with a platform built by a lawyer and an accountant.