Austrac has issued Public Legal Interpretation No. 4 of 2008 – What constitutes a reporting entity (pdf).

The purpose of the Public Legal Interpretation is to set out AUSTRAC’s views on the provisions of the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 as they relate to:
• who is a provider of a ‘designated service’; and therefore, who is a ‘reporting entity’
• what is meant by ‘carrying on a business’ and acting ‘in the capacity of’ a provider of designated services
• the obligation to lodge a compliance report.