A designated service is a service specified in section 6 of the AML/CTF Act (including items in the designated services table) that, when provided with a geographical link to Australia, triggers AML/CTF obligations for a reporting entity. For advisers, this generally includes arranging or dealing in financial products (e.g., investments or rollovers), while strategic advice alone, without execution, will generally not be a designated service in the absence of arranging, dealing in, or other involvement in the transaction chain, unless captured by a specific item (such as item 54).
Expanded Answer
A designated service is a specific activity listed under the AML/CTF regime that brings an entity within AUSTRAC’s scope. The regime applies based on whether the activity falls within a listed designated service, assessed in substance (what is actually done), rather than solely by reference to licensing status or labels. If a service is designated, AML/CTF obligations apply, including customer identification, ongoing due diligence, and reporting. An entity becomes a reporting entity for AML/CTF purposes when it provides a designated service.
For financial planners and licensees, common examples include arranging for a client to acquire a financial product (such as placing funds into a managed investment), dealing on behalf of a client (such as executing switches or superannuation rollovers), or issuing financial products where this is captured under the designated services table. These activities typically trigger AML/CTF obligations because the adviser is sufficiently involved in the transaction chain. By contrast, providing strategic or personal advice alone, without arranging, dealing in, or facilitating execution, will generally not constitute a designated service. Referrals without further involvement may fall outside scope depending on the structure; however, this is a high-risk boundary area, particularly where the adviser facilitates introductions, influences product selection, or receives benefits linked to the transaction.
A key nuance is SMSF advice. Certain SMSF-related advice (e.g. advice that results in establishing or contributing to an SMSF) may constitute a designated service under item 54 where it leads to the acquisition of a superannuation interest. In these circumstances, the advice itself can be captured as the designated service, even where no separate product transaction has yet occurred. This means AML/CTF obligations may arise earlier than expected, because the trigger is the provision of the designated service (i.e. the advice leading to acquisition), rather than the later execution of a financial transaction. Risk increases where advisers facilitate SMSF establishment, coordinate rollovers, or are involved in implementation steps. For further context, see AML/CTF financial planners Australia and Five AML questions you must be able to answer.
Why it matters
Designated services determine whether AML/CTF obligations apply at all. Misunderstanding boundaries, particularly the distinction between advice-only and execution, and SMSF advice under item 54, can lead to gaps in customer due diligence and increased regulatory scrutiny.
Practical guidance
- Map advice and implementation workflows to identify where designated services arise, including SMSF advice triggers
- Distinguish clearly between advice-only, referral, and execution activities in policies and procedures
- Test real client scenarios (e.g. SMSF establishment and rollovers) to confirm AML/CTF obligations are applied consistently
Further reading
What’s changing in 2026 under the AML/CTF reforms?