AML/CTF Compliance
For most accounting firms, you do not need to run every available verification for every client. AML/CTF laws require a risk-based approach — perform enough checks to identify the client, understand the risk, and screen for sanctions/PEPs.
Verification Types by Requirement Level
Required
Identity Verification
Verify the individual's identity. This is the core KYC requirement.
ASIC Organisation Verification
Confirms the company exists and registration details.
ABR Lookup
Verifies ABN/business details. Free, so there's little reason not to use it.
Multi-level UBO Report
Identifies the Ultimate Beneficial Owners, a key AML requirement.
PEP & Sanctions Screening
One of the most important AML/CTF checks.
Optional
Watchlist Screening
Usually included with PEP/Sanctions
DVS Verification
Helps verify Australian identity documents with government records
Biometric Verification
Improves fraud prevention but isn’t legally required in most cases.
Liveness Check
Used to prevent spoofing during online identity verification.
eKYC Verification
Depends on provider. Often this includes identity, DVS and document verification.
Not Usually Required
VEVO Check
Verify the individual's identity. This is the core KYC requirement.
International Document Check
Needed only for overseas identity documents.
Pass Rate Booster
Provider feature, not an AML requirement.
PEP Media Screening
Helpful for enhanced due diligence but not required for every client
Standard low-risk verification
Individual client
REQUIRED CHECKS
- Identity Verification
- DVS Verification (if Australian ID)
- PEP & Sanctions Screening
COST BREAKDOWN
Identity Verification
$5.00
$1.02
PEP & Sanctions Screening
$0.66
= AUD $6.68 per client
Entity and UBO verification
Company Client
REQUIRED CHECKS
- ASIC Organisation Verification
- ABR Lookup
- Multi-level UBO Report
- Identity Verification (per director/UBO)
- PEP & Sanctions (per director/UBO)
COST BREAKDOWN
ASIC Verification
$26.25
DVS Verification
$57.00
Multi-level UBO Report
$5.00
PEP/Sanctions (per person)
$0.66
Note: More expensive because identifying and verifying beneficial owners is often the costliest part.
Risk-Based Verification Workflow
Recommended Default AML Module
Individual
- Unlimited users
- DVS (if Australian ID)
- PEP & Sanctions Screening
Company
- ASIC Verification
- ABR Lookup
- UBO Report
- Identity Verification for each beneficial owner/director
- PEP & Sanctions Screening for each beneficial owner/director
Note
Everything else can be treated as optional or triggered by a high-risk assessment.
That approach is typically sufficient for standard, low-risk accounting clients while still allowing firms to add enhanced due diligence when circumstances warrant it.
