Our New Client Identity Verification Process

New AML/CTF laws are reshaping client identity verification for professional service firms, and we are ready for the change.

From 1 July 2026, new Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) obligations will apply to accounting and legal professionals across Australia. AUSTRAC is introducing these reforms as part of a broader effort to strengthen protections against fraud, identity misuse and financial crime.

What This Means For You

These changes will create obligations for clients, as before we can commence or continue providing certain services, we may need to verify your identity.

This is not about distrust, it is now a standard legal requirement across the accounting and legal industries, similar to processes already used by banks and financial institutions.

Our goal is to make this process are simple, secure, fast and transparent as possible for all our clients.

How Verification Works

If identity verification is required, our team will send you a secure email containing a link to an onboarding form through one of our chosen verification platforms.

Once opened, you will be prompted to:

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

This is a relatively quick process, taking approximately 5-10 minutes.

Ongoing Verification: In some cases, we may need to verify your identity again. For example, if a significant period of time has passed since initial verification, or you engage us for a new service.

Secure Verification Platforms

To help us manage these new obligations securely and efficiently, Aintree Group will be using Nagaris and InfoTrack for digital identity verification. Nagaris will be used for our accounting clients, and InfoTrack will be used for our legal clients.

Using digital verification platforms like these help us to:

Reduce paperwork and manual handling.
Protect your information with secure encrypted technology.
Speed up onboarding and engagement processes.
Provide a more convenient experience for clients.

Read Nagaris Instructions – Accounting Clients

Read InfoTrack Instructions – For Legal Clients

Other Important Considerations

Are you a Politically Exposed Person (PEP)?

Before completing your identity verification, it’s important to determine whether you or your representative is a Politically Exposed Person (PEP). The different types are listed below.

Please note family members and close business associates of persons who hold one of these positions are 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 & Privacy Matter

We understand that providing identification documents online can feel sensitive.

We have chosen to use purpose-built identity verification platforms 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.

Further Guidance

AUSTRAC:

To help you understand your obligations, and the obligations and responsibilities of businesses you use, refer to this resource from AUSTRAC.

Understand Your Obligations – AUSTRAC

Further Context:

To discover the broader AML/CTF changes and why AUSTRAC is introducing these laws, read our blog post below.

Verifying Client Identity from 1 July 2026

Questions?

If you have any concerns or questions about the identity verification process, please contact your Aintree Group adviser.

We are committed to making this transition as simple, secure and transparent as possible for our clients.

This is general advice only and has not been prepared with your individual situation or needs in mind. For personalised advice, we highly recommend that you seek professional guidance from a qualified adviser.

Our New Client Identity Verification Process

What This Means For You

How Verification Works

Secure Verification Platforms

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 & Privacy Matter

FAQs

Further Guidance

AUSTRAC:

Further Context:

Questions?

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What This Means For You

How Verification Works

Secure Verification Platforms

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 & Privacy Matter

FAQs

Further Guidance

AUSTRAC:

Further Context:

Questions?

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