CAAA Group’s approach to AML/CTF and KYC

From 1 July 2026, new anti-money laundering and counter-terrorism financing laws will apply to certain professional services provided by accountants and advisers in Australia.

As a result, the CAAA Group may be required to complete Know Your Customer (KYC) checks before providing certain services to clients.

These checks are part of Australia’s AML/CTF framework and are now a compliance requirement for all accountants in Australia.

What this means for our clients

Where the AML/CTF laws apply, we may need to collect and verify information about our clients, including individuals, companies, trusts, partnerships and other entities. Depending on the client and the services required, this may include information about:

identity documents;
directors, trustees, partners or authorised representatives;
beneficial owners or controlling persons;
the nature and purpose of the work being requested; and
in some cases, source of funds, source of wealth or other supporting information.

Not every client will be asked for the same information. The information required will depend on the type of client, the services being provided and the level of risk assessed under the CAAA Group’s AML/CTF Program.

Our KYC process

Our process is designed to be clear, secure and as efficient as possible. In most cases, the process will involve:

requesting the relevant information or documents;
verifying the information provided;
asking for clarification if anything further is required;
completing our AML/CTF assessment; and
proceeding with the relevant services once the required checks are complete.

In some circumstances, we may not be able to commence or continue providing certain services until the required checks have been completed.

Existing clients

Existing clients may also be asked to provide updated or additional information from time to time. This may occur where there has been a change in ownership, control, instructions, services or other relevant circumstances.

Privacy and data handling

We take privacy, confidentiality and data security seriously. Information collected for AML/CTF and KYC purposes will be handled in accordance with Australian privacy laws, our professional obligations, our engagement terms and our internal data handling procedures.

Access to AML/CTF information is limited to authorised personnel and approved service providers where required for verification, compliance, technology or professional purposes.

Our commitment

The CAAA Group is committed to meeting its AML/CTF obligations in a way that is practical, professional and respectful of our client relationships. We appreciate our clients’ cooperation as these new requirements are introduced across the accounting and advisory profession.

If you have any questions about our AML/CTF or KYC process, please contact your CAAA Group adviser or contact us through our website.

AML/CTF and KYC Client FAQs

At the CAAA Group, we are committed to providing tailored solutions, specific advice and premium service while meeting our legal, professional and regulatory obligations.

From 1 July 2026, new anti-money laundering and counter-terrorism financing laws will apply to certain professional services provided by accountants and advisers in Australia. As part of these changes, the CAAA Group may be required to complete Know Your Customer (KYC), checks before providing certain services.

These FAQs explain what this may mean for our clients.

1. Why is CAAA Group asking for my ID?

We may be required to verify your identity as part of Australia’s AML/CTF laws.

These checks are required under the new AML compliance requirements for Accountants. For individuals, this may include providing identity documents such as a driver’s licence, passport or other accepted identification documents.

2. I have worked with the CAAA Group before. Why am I being asked now?

The AML/CTF requirements are new for many professional services providers, including accounting and advisory firms.

Even if you are an existing client, we may need to collect or update information to meet our legal obligations. This may occur when we are providing a service covered by the AML/CTF laws, where your circumstances have changed, or where our internal risk assessment requires updated information.

This is a standard regulatory requirement and does not mean that anything is wrong.

3. Does every client need to complete KYC checks?

Not every client will be asked for the same information.

The information we request will depend on the type of client, the structure involved, the services being provided and the level of risk assessed under the CAAA Group’s AML/CTF Program. For example, an individual client may only need to provide basic identity information, while a company, trust, partnership or self-managed superannuation fund may require additional information about ownership, control or authorised representatives.

4. What information might I be asked to provide?

Depending on your circumstances, we may ask for information such as:

identity documents;
date of birth and residential address;
company, trust, partnership or SMSF details;
details of directors, trustees, partners, beneficiaries, members or authorised representatives;
information about beneficial owners or controlling persons;
information about the nature and purpose of the work we are being asked to perform; and
in some cases, information about source of funds, source of wealth or the background to a particular transaction or matter.

We will let you know what is required in your particular circumstances.

5. What if I am acting for a company, trust, partnership or SMSF?

Where you are acting for an entity, we may need to understand who owns, controls or acts on behalf of that entity.

This may include collecting information about directors, shareholders, trustees, beneficiaries, partners, members, authorised representatives or other controlling persons. These checks help us understand the people behind the structure and are part of our legal obligation to assess AML/CTF risk.

6. What is a beneficial owner?

A beneficial owner is generally an individual who ultimately owns or controls a client or has effective control over a client structure.

For companies, this may include individuals who own or control shares or voting rights. For trusts, this may include trustees, appointors, beneficiaries or other persons who can control or influence the trust.

The exact information required will depend on the structure and the services being provided.

7. What is “source of funds” and why might you ask for it?

Source of funds refers to where the money for a particular transaction or matter is coming from. For example, this may include savings, sale proceeds, business income, a loan, inheritance, investment proceeds or another legitimate source.

We may ask for source of funds information where it is required by law, where the transaction or matter presents a higher AML/CTF risk, or where further clarification is needed to complete our assessment.

8. What is “source of wealth”?

Source of wealth refers to how a person or entity has accumulated their overall wealth or financial position over time. This is different from source of funds, which relates to the money being used for a particular transaction or matter.

We will only ask for this information where it is relevant to the AML/CTF assessment.

9. Do I need to provide this information before work begins?

In many cases, yes.

Where the AML/CTF laws apply, we may need to complete required checks before we can commence or continue providing certain services.

If further information is required, we will let you know as early as possible so that any delay can be minimised.

10. What happens if I do not provide the requested information?

If we are unable to collect or verify the information required under the AML/CTF laws, we may not be able to commence or continue providing certain services. These requirements apply because the CAAA Group is required to comply with its legal obligations. They are not optional.

If you have concerns about a request, please contact your CAAA Group adviser so we can explain what is required and why.

11. I’ve already had a VOI check? Isn’t that the same as KYC?

No. Verification of Identity, or VOI, is usually only one part of a broader KYC process. KYC is more comprehensive. It may require us to understand who the client is, who owns or controls the client, who is authorised to act, the nature and purpose of the services being provided, and whether any AML/CTF risks need to be managed.

Check	VOI	KYC
Confirms identity using ID documents	Yes	Yes
May include proof of address	Sometimes	Yes, where required
Considers who owns or controls an entity	No	Yes, where required
Considers the nature and purpose of the work	No	Yes
Includes AML/CTF risk assessment	No	Yes
May include source of funds or source of wealth	No	Yes, where required
May involve ongoing monitoring or updates	No	Yes

12. Will I need to complete KYC more than once?

You may be asked to update information from time to time. This may occur if there is a change in your circumstances, ownership, control, authorised representatives, instructions, services or risk profile.

We may also need to refresh information periodically as part of our ongoing AML/CTF obligations.

13. Is my information secure?

We take privacy, confidentiality and data security seriously.

Information collected for AML/CTF and KYC purposes will be handled in accordance with applicable Australian privacy laws, our professional obligations, our engagement terms and the CAAA Group’s internal data handling procedures.

Access to AML/CTF and KYC information is limited to authorised personnel and approved service providers where required for verification, compliance, technology or professional purposes.

14. Will my information be shared with anyone?

Your information may be used for client onboarding, identity verification, compliance checks, risk assessment, record-keeping and related professional obligations. In some cases, we may use approved external service providers to assist with secure identity verification, document collection or compliance processes.

We may also be required by law to report certain matters to AUSTRAC or another relevant authority.

15. What is AUSTRAC?

AUSTRAC is Australia’s financial intelligence agency and AML/CTF regulator.

It oversees Australia’s AML/CTF regime and works to detect, deter and disrupt money laundering, terrorism financing and other serious financial crime.

16. Does being asked for KYC information mean the CAAA Group suspects something is wrong?

No.

KYC checks are a standard part of the AML/CTF framework. Being asked to provide information does not mean that you are suspected of wrongdoing. In most cases, it simply means that we need to collect or verify information to comply with our legal obligations.

17. What should I do if I am unsure about a request?

Please contact your CAAA Group adviser.

We will explain what information is required, why it is needed and how it should be provided.

18. Who can I contact about AML/CTF or KYC?