AML/CTF Client Verification Support Page

From 1 July 2026, new Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) obligations will apply to accounting and legal professionals across Australia, under the Tranche 2 Reforms.

AUSTRAC is introducing these reforms as part of a broader effort to strengthen protections against fraud, identity misuse and financial crime.

Source: AUSTRAC

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AML/CTF Client Verification Support Page

Tranche 2: Explained

We wanted to explain an important distinction about Australia’s AML/CTF reforms.

Some businesses have been subject to AML/CTF regulation for some time. Others are newly regulated under the reforms and came into the regime from 1 July 2026. Here’s what that means for you.

Existing Regulated Businesses (Tranche 1)

Aintree Group Wealth is already regulated; we’ve already built the systems and processes to meet AUSTRAC’s expectations. The ongoing obligations include:

Knowing our customers: verify who they are and assess any money laundering or terrorism financing risks they may pose.
Monitoring activity: we’re watching for unusual or suspicious transactions and reporting where required.
Maintaining an AML/CTF program: our business has policies, procedures and governance in place, with a nominated compliance officer.
Keeping records: we hold customer information and transaction records to demonstrate compliance.

Newly Regulated Businesses (Tranche 2)

Aintree Group Chartered Accountants and Aintree Group Legal are coming into regulation for the first time; so we’ve had to build an AML/CTF program from the ground up. This involves:

Enrolling with AUSTRAC.
Building our AML/CTF program: developing policies and procedures that fit our specific services and business model.
Implementing customer due diligence: putting in place processes to identify and verify our clients.
Training our team: making sure everyone understands their role in keeping our business compliant.
Setting up monitoring and reporting: establishing systems to detect and report suspicious activity.

Why do we charge an AML/CTF fee?

The new AML/CTF Tranche 2 requirements create additional compliance work. In practical terms, the fees charged help cover the time and systems needed to complete Verification of Identity (VOI), Know Your Client (KYC) and Know Your Business (KYB) checks, keep records up to date and monitor for changes throughout the relationship.

What is checked:

We are required to confirm the identity of the client and, where relevant, any beneficial owners, controllers and authorised representatives. For businesses, we also check ownership and control details, registration status and the nature of the business.

How the checks are carried out:

We compare the information provided with reliable independent sources and screening tools, and we may ask for further documents if anything needs to be clarified or verified.

Information reviewed:

This can include photo identification, company extracts, ABN and ACN details, trust deeds, constitutions, director and shareholder details, and, where needed, source of funds or source of wealth information.

Risk indicators and verification:

We look for inconsistencies, unusual ownership structures, overseas links, higher-risk jurisdictions, sanctions, politically exposed persons (PEPs), or adverse media hits, and transaction patterns that do not fit the profile.

Ongoing monitoring:

Checks are refreshed when circumstances change, and records are kept so we can continue monitoring the relationship and meet our legal obligations.

Record Keeping and Compliance Administration:

The legislation requires us to securely retain evidence of all verification activities, risk assessments and compliance records for prescribed periods. We also maintain systems, procedures and team training to ensure we continue meeting our legal obligations.

These checks are part of the compliance obligations we must meet, and they involve specialist processes, documented reviews and ongoing governance. The fees charged help cover that work so we can meet our obligations consistently and provide a service that remains compliant, reliable and sustainable.

How to Verify Your Identify for AML/CTF Purposes via Nagaris:

Please note: These instructions are for Aintree Group accounting clients only. If you are a legal client, please refer to these instructions to verify via InfoTrack instead.

If identity verification is required, our team will send you a secure email containing a link to an onboarding form. This link will remain valid for 7 days. You will need to:

Provide personal details,
Answer a few compliance-related questions, and
Verify your identity.

This is a relatively quick process, taking approximately 10 minutes.

Step 1: Open your secure verification link.

You will be sent an email from Nagaris containing your secure link.

Step 2: Personal details and compliance questions.

You will need to provide your:

Name;
Date of birth;
Residential address;
Country of residence;
PEP (Politically Exposed Person) self-declaration;
Source of funds; and
Foreign dealings.

You will also need to fill out the:

Acting-on-behalf (third party) questions, and
Declarations.

Here’s what it will look like for you:

Step 3: Complete an identity check.

You will then need to verify your identity. This will include a:

Government-ID document check;
Liveness check; and
Biometric face match.

You must provide one of the following for yourself and any representative:

Option 1: One primary photographic identification document.
Option 2: Two primary non-photographic identification documents along with a reference.
Option 3: One primary non-photographic identification document and a secondary identification document, along with a reference.

If you are the client’s representative, provide the above documents for yourself and your client.

All documents provided must be an original or a reliable copy. This includes physical copies or electronic sources.

See an overview of the different document types below:

Primary photographic identification documents

• Australian passport
• Australian proof of age card
• Australian driver’s licence
• Foreign passport
• Foreign identity card

Primary non-photographic identification documents

• Australian birth certificate or birth extract
• Australian citizenship certificate
• Australian concession card (pensioner concession card, health care card, senior’s health card)
• Medicare card
• Veteran card
• Change of name certificate
• Marriage certificate
• Foreign birth certificate
• Foreign citizenship certificate

Secondary identification documents

• Utility notice issued in the last 3 months
• Council rates notice issued in the last 3 months
• Australian bank statement issued in the last 3 months
• Notices issued by a Commonwealth, state, territory or local government body issued in the last 3 months
• Income tax assessment notice issued by the Australian Taxation Office (ATO) in the last 12 months
• Payslip or letter from employer containing the individual’s name issued in the last 3 months

Here’s what it will look like for you:

Step 4: Submit your verification.

After you submit your verification, the system securely processes it and shares the results with our team.

Ongoing Verification

If a significant period of time has passed since initial verification, or we are providing a new service, we may need to verify your identity again.

Other Important Considerations

Are you a Politically Exposed Person (PEP)?

Before completing your verification, consider if you or your representative are a PEP, with the different types listed below.

Note: Family members and close business associates of persons who hold one of these positions are also considered politically exposed persons.

Foreign PEP

A foreign PEP is an individual who holds or has held a prominent office or position or public function in or for the legislature, executive or judiciary of a foreign country.

This includes an individual who holds or has held any of the following offices or positions:

• Head of state or head of government.
• Member of the executive council of government.
• Member of a legislature.
• Minister, deputy minister or equivalent office or position.
• Judge of a supreme court, constitutional court or other court of general jurisdiction or last resort.
• Ambassador, high commissioner or charge d’affaires.
• High ranking military officer.
• Head or board member of a government body.
• Head or board member of a state‑owned company or a state‑owned bank.
• Member of a governing body of a political party represented in a legislature.

A foreign PEP is also a family member of an individual listed above or an individual who is known (based on information that’s public or readily available) to have:

• Joint beneficial ownership of a body corporate or legal arrangement with an individual listed above.
• Sole beneficial ownership of a body corporate or legal arrangement on behalf or for the benefit of an individual listed above.
• Any other close business relations with an individual listed above.

Domestic PEP

A domestic PEP is an individual who is in or has been in the following office or position:

• Member of the legislature of the Commonwealth or a state or territory.
• Member of the governing body of a political party represented in the legislature of the Commonwealth or a state or territory.
• Governor‑General.
• Governor of a state.
• Administrator of a territory.
• Justice of the High Court.
• Judge of the Federal Court of Australia.
• Judge of the Supreme Court of a state or territory.
• Accountable authority, or member of the accountable authority, of a Commonwealth entity within the meaning of the Public Governance, Performance and Accountability Act 2013 (PGPA Act) (for example a Secretary of a Department of State or parliamentary department).
• Member of the governing body of a wholly‑owned Commonwealth company within the meaning of the PGPA Act.
• Head (however described) of a department of state or territory, or an agency or authority of a state or territory that has a prominent public function.
• Head (however described) of a local government council in a state or territory.
• The chair of the board, chief executive officer or chief financial officer of a company or other incorporated body that’s wholly‑owned or majority‑owned by a state or territory.
• Chief of the Defence Force, Vice Chief of the Defence Force, Chief of Navy, Chief of Army or Chief of Air Force.
• Officer of the Navy of the rank of Vice Admiral or a higher rank.
• Officer of the Army of the rank of Lieutenant General or a higher rank.
• Officer of the Air Force of the rank of Air Marshal or a higher rank.
• Any of the following offices of the Commonwealth in a foreign country, or to a public international organisation, to which appointments are made by the Governor‑General:
– Ambassador
– High Commissioner
– Consul‑General
– Australian representative
– special representative
– representative
– permanent representative
– Chargé d’Affaires

A domestic PEP is also a family member of an individual listed above, or an individual who is known (based on information that’s public or readily available) to have:

• Joint beneficial ownership of a body corporate or legal arrangement with an individual listed above.
• Sole beneficial ownership of a body corporate or legal arrangement on behalf or for the benefit of an individual listed above.
• Any other close business relations with an individual listed above.

International organisation PEP

An international organisation PEP is an individual that is entrusted or has been entrusted with a prominent public function, position or office of a public international organisation. This includes a head, deputy head or board member in a public international organisation, such as a United Nations body.

An international organisation PEP is also a family member of one of these individuals, or an individual who is known (based on information that’s public or readily available) to have:

• Joint beneficial ownership of a body corporate or legal arrangement with an individual entrusted with a prominent public function, position or office of a public international organisation.
• Sole beneficial ownership of a body corporate or legal arrangement on behalf or for the benefit of an individual entrusted with a prominent public function, position or office of a public international organisation.
• Any other close business relations with an individual entrusted with a prominent public function, position or office of a public international organisation.

Family members

A family member includes:

• A spouse, de facto partner, or equivalent under any applicable law of a foreign country, of the individual.
• A child of the individual.
• A spouse or de facto partner, or equivalent under any applicable law of a foreign country, of a child of the individual.
• A parent of the individual.

Different Requirements For Trusts and Entities

Additional information will typically be required for trusts and entities. However, your Aintree Group adviser will prefill as much of this as possible, on your behalf.

Nonetheless, you will need to provide identity documents.

Explore the documents you will need to provide below:

Identity documents for trusts

Please provide one or more of the following:

• A copy of the trust deed, or foreign equivalent instrument
• A disclosure certificate that verifies information about the trust
• Letters or documents from the trust’s professional services firms
• A copy of recent trustee resolutions
• The memorandum of trust

Identity documents for body corporates, partnerships or unincorporated associations

Please provide one or more of the following:

• A copy of the client’s constitution
• A copy of the client’s charter
• A copy of the client’s rules
• A copy of distribution(s) of member statements
• A copy of the partnership agreements
• Certificate of Incorporation
• Certificate of Good Standing
• Memorandum and articles of association
• Evidence of the source of funds/wealth. For example, bank statement, tax assessment etc.

Your Security Matters

We understand that providing identification documents online can feel sensitive.

We chose a purpose-built identity verification platform to help keep your information secure.

Your information is:

Submitted through encrypted systems.
Protected using bank-grade security measures.
Managed in accordance with Australian privacy obligations.
Only collected where required for compliance purposes.

We only request the information necessary to meet our legal obligations under the AML/CTF framework.

FAQs

Why are you asking me for ID now?

From 1 July 2026, accounting and legal firms will be legally required to complete identity verification for certain regulated services.

Refer to this breakdown from AUSTRAC for more information.

I’ve been a client for years, why do I need to do this?

These obligations apply regardless of how long we have worked together. In some cases, we may also need updated or refreshed information to comply with the new requirements.

How long does it take?

Most clients complete the process in 10 minutes.

Do I need to create an account?

In most cases, no ongoing account setup is required. You simply follow the secure verification link provided to you.

What if I’m uncomfortable completing this digitally?

Please contact our team. We will work with you to discuss alternative options where available.

I don’t have the documents I need. What can I do?

You can prove your identity in alternative ways if you:
• Can’t get standard identification information or evidence.
• Can’t access standard identification information or evidence due to circumstances beyond your control.
• Have inconsistent details across their identification documents.

Other documents that can verify your identity could include, but aren’t limited to, any of the following:

• A reference from another individual *must meet specific requirements*
• Government correspondence, including documents from state or territory corrective services
confirming your identity with reputable organisations or bodies known to you. For example, Aboriginal and Torres Strait Islander organisations or community health organisations
• A community ID or organisation membership card for Aboriginal and Torres Strait Islander peoples.
• Recently expired identification.
• A self-attestation of your identity.

I am acting on behalf of a client. What do I need to do?

If you are acting on behalf of the client, evidence of authority to act may include:

• For any general appointment:
– A letter, agency agreement or other authorisation document from the client establishing that you have authority to act.
– Written confirmation from a reliable third party such as a legal practitioner, accountant or other professional, that you have authority to act.

•Written confirmation from your employer that you are authorised to act, if authority to act arises from your employment.

• The document granting you power of attorney, if authority to act arises from a power of attorney.

• An extract of the legislation giving you authority to act, if authority to act arises from legislation.

AML/CTF Client Verification Support Page

Tranche 2: Explained

Existing Regulated Businesses (Tranche 1)

Newly Regulated Businesses (Tranche 2)

Why do we charge an AML/CTF fee?

What is checked:

How the checks are carried out:

Information reviewed:

Risk indicators and verification:

Ongoing monitoring:

Record Keeping and Compliance Administration:

How to Verify Your Identify for AML/CTF Purposes via Nagaris:

Step 1: Open your secure verification link.

Step 2: Personal details and compliance questions.

Here’s what it will look like for you:

Step 3: Complete an identity check.

You must provide one of the following for yourself and any representative:

See an overview of the different document types below:

Here’s what it will look like for you:

Step 4: Submit your verification.

Ongoing Verification

Other Important Considerations

Are you a Politically Exposed Person (PEP)?

Different Requirements For Trusts and Entities

Explore the documents you will need to provide below:

Your Security Matters

FAQs

Connect

Office Access – June 2026