AML/CTF Requirements
Understanding the AML/CTF Act and why we need your information
What are these laws and why do they matter?
Australia’s Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) laws are designed to protect the financial system from criminal exploitation. Criminals often target legitimate businesses to disguise illegal funds, which fuels serious crimes like fraud, drug trafficking, and human exploitation.
To combat this, the Australian Government requires accounting, advisory, and professional services firms to legally verify client identities, assess the risk of money laundering, and monitor certain transactions. As a member of the Moore Australia network, we are committed to maintaining the highest standards of integrity and professionalism in preventing these financial crimes.
This isn’t about ticking boxes or singling anyone out. By applying these consistent checks to everyone, we are doing our part to keep illicit money out of our communities and ensure Australia aligns with global financial standards.
When does this apply and what we may ask for?
Not every service we provide requires these checks. However, when you engage us for specific regulated services – such as, but not limited to, setting up new companies or trusts, acting as a nominee, or providing a registered office – we are legally required to understand exactly who we are doing business with.
Depending on the services you require, we may ask for:
- Proof of Identity: A form of primary photographic identification (for example a passport or driver’s licence) and proof of address.
- Entity Documentation: If you are acting on behalf of a company, trust, or association, we will require documents such as company extracts or trust deeds. We are legally required to trace and identify the natural persons who ultimately own or control the entity.
- Source of Wealth/Funds: For certain complex corporate structures or higher-risk engagements, we may ask for a brief explanation or evidence regarding where the funds for a transaction originated.
How we verify your information securely
We know your time and privacy are highly valuable. To make this process as seamless and secure as possible, we utilise approved digital identity solutions to conduct our checks.
When you provide your identity documents digitally, our systems may use advanced anti-spoofing checks and biometric verification to ensure you are exactly who you claim to be, protecting you against identity theft and the rising risk of deepfake fraud.
How your data is handled
We take the security of your personal information incredibly seriously.
- We only collect the minimum information required to meet our legal obligations.
- Your data is stored securely and handled in strict confidence.
- Your information is used exclusively for regulatory compliance purposes and is never traded or used for marketing.
What happens next?
If we require you to provide any of this information, our team will guide you through the process and provide a secure link to upload your documents. If anything is unclear or you have any concerns, please just ask.
Thank you for your cooperation in helping us meet these important legal requirements.
Frequently Asked Questions
Under the Australian Government’s Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) Act, professional services firms are legally required to verify the identity of their clients before providing certain services. This is a mandatory compliance step designed to protect the Australian financial system from criminal exploitation.
The new Tranche 2 AML/CTF laws apply to specific services (such as, but not limited to, company/trust formation, nominee arrangements, or providing a registered office) regardless of how long we have worked together. The law requires us to independently verify and document your identity and ownership structures under the new standards. If your information is up to date, this process will be very quick.
If you are engaging us on behalf of a non-individual entity, we are required by law to look behind the corporate structure. We must collect relevant registry extracts (such as ASIC extracts or trust deeds) to trace and identify the natural person(s) who ultimately own or control the entity. If the entity’s ownership is highly complex or no individual beneficial owner exists, we are required to identify and verify the CEO or equivalent senior officer instead.
For certain higher-risk transactions or complex ownership structures, the law requires us to conduct Enhanced Customer Due Diligence. This means we may need to ask for a brief explanation or supporting documents to verify where the funds for a transaction originated to ensure they are consistent with your known profile.
A Politically Exposed Person (PEP) is someone who holds a prominent public or government position. As part of our mandatory screening, we must conduct searches to check if our individual clients or beneficial owners are PEPs, or if they have foreign affiliations, as these roles carry specific regulatory requirements.
Absolutely. We take the security of your data very seriously. To verify your identity securely, we utilise digital identity solutions equipped with advanced anti-spoofing checks and secondary verification methods. This ensures you are exactly who you claim to be and protects you against identity theft and the rising risk of deepfake fraud. Your information is used strictly for regulatory compliance purposes.
We understand that gathering this documentation can take a little time. However, if we cannot complete the required Customer Due Diligence (CDD) steps to verify your identity or ownership structure, we are legally required to decline the new engagement or stop providing the designated services.