Most of what’s required is information you already have — and in many cases, we may already have it on file.
If there’s one thing that will determine whether the new AML process is quick and painless or slow and frustrating, it’s whether the necessary documents are available when the time comes.
The good news is that most of what’s required is information that already exists. And in many accounting practices, key documents like trust deeds, company constitutions, ASIC extracts, and entity records may already be on file at our office. Where that’s the case, we’ll pull together what they already have and only come to you for anything that’s missing or needs updating.
Here’s a guide to what’s typically required, based on your situation.
What everyone needs
- Current photo ID — driver’s licence or passport for every key individual
- Date of birth and residential address
- Up-to-date contact details — legal name, trading name, phone, email, postal address
- Tax File Number and ABN or ACN — where relevant
- An explanation of the nature and purpose of the engagement
If you operate through a company
- Recent ASIC company extract — showing directors, shareholders, registered office, and share structure
- Beneficial ownership details — anyone who owns or controls 25%+ directly or indirectly
- Group structure chart — if there are holding companies, related entities, or overseas parents
- Photo ID for each director and each beneficial owner
Note: We may already have your ASIC extract, company constitution, or shareholder details on file. They’ll review what’s available and let you know if anything needs to be updated or supplemented.
If you operate through a trust or SMSF
- Trust deed and any amending deeds
- Names and details of trustees, appointor/principal, and beneficiaries or classes of beneficiaries
- Settlor details — if the settlor retains any ongoing role or interest
- For SMSFs: latest ATO registration notice and complete list of members
- Photo ID for all trustees and key individuals
- If corporate trustee: full company identification as above
Note: Trust deeds, amending deeds, and trustee details are sometimes held at our office. Where we have these records, we’ll use them and only ask for anything that’s not already on file.
If you’re a sole trader or in a partnership
- Business name registration details and ABN
- Partnership agreement — if one exists
- Names, dates of birth, and addresses of all partners
- Photo ID for each partner or the sole trader
What we might ask for in addition
Depending on your risk profile, we may also request:
- Source of funds — where the money for a specific transaction is coming from
- Source of wealth — how your overall assets have been accumulated
- Purpose of the engagement or transaction
- Politically Exposed Person (PEP) declaration
- A list of countries where owners, operations, bank accounts, or major customers are located
These questions aren’t accusations. They’re standard risk-assessment tools that the legislation requires when circumstances call for it.
The bottom line
You don’t need to rush out and gather everything right now. The AML checks are triggered when you request a designated service — not before.
When the time comes, we’ll let you know exactly what’s needed. In many cases, they may already have some of the documentation on file and will work with whatever records are available first. The main thing you can do to keep things moving is make sure your photo ID is current and your contact details are up to date — those are the items we’re least likely to already have on file.
Don’t Worry — We’ll Guide You Through It
We know this looks like a long list, but please don’t be overwhelmed. We may already have some of these documents on file — trust deeds, company constitutions, ASIC records, and more. When a designated service triggers the new requirements, we’ll review whatever records we have and only ask you for anything that’s missing. The main thing you can do now is make sure your photo ID is current. Beyond that, we’ll handle it together when the time comes.