Know who your client is
Check each client's identity before you provide the service — usually a photo ID such as a driver licence or passport, confirmed as genuine and matched to the person.
Guide · Tranche 2 AML/CTF
AML checks for small firms under the new rules
Since 1 July 2026, many Australian accountants, lawyers, conveyancers and company service providers must check their clients' identity under the expanded AML/CTF laws. This guide explains, in plain English, what that means for a small practice — and how to do it without a monthly software subscription.
Who is affected
The new rules cover certain services, not whole professions. You are likely affected if you are:
- Accountants and bookkeepers who set up companies or trusts, or handle client money
- Lawyers and law firms acting in property, company or trust matters
- Conveyancers handling property transactions
- Real estate agents involved in buying and selling property
- Trust and company service providers, including company registration agents
Check AUSTRAC's guidance to confirm exactly which of your services are covered.
What you need to do for each client
Know who is behind a company or trust
For companies and trusts, identify the people who ultimately own or control them (commonly anyone holding 25% or more) and check their identity too.
Screen for sanctions and risk
Check the client against sanctions lists, consider whether they are a politically exposed person, and look for adverse news. Assess the client's risk level.
Keep the records
Keep the evidence of what you checked, when and the result, so you can show AUSTRAC or an auditor if asked. Records are generally kept for seven years.
Do you need a subscription?
Most AML software is sold as a monthly plan, which you pay whether you onboard one new client or fifty. For a small firm that only needs a handful of checks, paying per check is usually simpler — and the fee can be passed on to the client as a disbursement.
Enliven Co charges $20 per individual and $30 per business (KYB). No subscription, no minimum volume.
How it works with Enliven Co
- 1. Send a secure link — enter the client's name, email and mobile; they receive a single-use link.
- 2. Client verifies on their phone — they photograph their ID and take a live selfie. No account or app needed.
- 3. Screening and certificate — sanctions screening against the official DFAT, UN and OFAC lists, a PEP and adverse media first-pass for your review, and a downloadable certificate for the client file.
Quick client checklist
- Confirm whether the service you are providing is covered by the new rules
- Collect the client's full legal name, date of birth and residential address
- Verify a photo ID document and match it to the client
- For companies and trusts, identify owners and controllers and verify them
- Screen against official sanctions lists and check for PEP status and adverse media
- Record the client's risk rating and when you will review it
- Save the evidence and certificate to the client file
This guide is general information, not legal advice. Your firm remains responsible for its own AML/CTF program. See AUSTRAC's website for official guidance. More about our AML verification.