AML/KYC and the First PBC List: One Onboarding Sequence
Verification and document requests are usually treated as separate onboarding steps. Running them as one sequence stops delays before the work even starts.
Most firms treat the two halves of client onboarding as unrelated errands. Someone in the office runs the identity checks for AML/KYC, and someone else — usually later, often when the job is already open — sends the first PBC (provided-by-client) request for source documents. The two happen in different tools, on different days, chased by different people.
The result is a slow, leaky start. A client verifies their ID quickly but the document request doesn't land for a week. Or the documents arrive before you've completed verification, so you're technically working on a file you can't yet act on. The job looks like it has started, but nothing is actually moving.
There's a better way to think about it: AML/KYC and the first PBC list are one onboarding sequence, not two. Handled together, they set the tone for the whole engagement and remove the most common early stall.
Why the two belong together
Both are gatekeepers. You can't lawfully proceed without the verification, and you can't practically proceed without the documents. If either is missing, the file is stuck — so it makes no sense to run them on separate clocks.
They also share the same problem: they depend entirely on the client doing something. And the client will do the minimum they're prompted to do. If you send them one email asking for ID and a separate email a week later asking for bank statements, you've doubled the number of times they can go quiet on you.
Combining the steps into a single, well-designed request has three benefits:
- One touchpoint for the client. They deal with everything the engagement needs from them in a single sitting, while their attention is fresh and their motivation is highest.
- One thing to chase. You track a single outstanding onboarding item, not two overlapping ones with different owners.
- A clean start condition. The job only becomes truly ready when verification is complete and the PBC list is returned. Nothing looks half-started.
The Australian AML context is changing
The AML/CTF regime is expanding to bring more accounting and advisory services into scope under the tranche-two reforms. Whatever your firm's exact obligations, the direction is clear: customer due diligence — verifying who your client is, and keeping a record of it — is becoming a formal, auditable part of onboarding rather than an informal favour.
That means two things for your process. First, the verification step needs a clear record: what was checked, when, and by whom. Second, it can't be an afterthought bolted on once the work is underway. Building it into your standard onboarding sequence now saves you retrofitting it later.
Designing the combined onboarding request
Think of it as a single package the new client receives once you've won them. It should contain:
1. Identity and verification
Whatever your KYC policy requires — identity documents for individuals, ABN/ACN and structure details for entities, and confirmation of beneficial owners where relevant. Ask for it in a form you can retain and reference.
2. The engagement-specific PBC list
Not a generic "send us your paperwork" note, but a tailored list driven by the work you've been engaged to do. A new BAS client needs different things from a new SMSF or a new company tax client. The list should be specific enough that the client knows exactly what "done" looks like.
3. A single, clear deadline and channel
One due date, one place to upload. Splitting documents across email, text and a portal login guarantees things get lost.
Why the PBC list should be a template, not a fresh write-up
The temptation is to hand-write the document request for every new client. Don't. The list for a given service is almost identical every time — the variation is the client's name and a couple of specifics. Writing it from scratch each onboarding wastes time and, worse, means the list quietly drifts. One team member asks for last year's financials, another forgets to, and your onboarding quality depends on who happened to do it.
Standardise the PBC list per service so it becomes part of the package. This is where account practice management software earns its place: the request template, the verification checklist and the due date all attach to the job automatically when the engagement is signed. The same discipline you'd apply to client accounting work — consistent, repeatable, documented — applies to the request that starts it.
Make the list chase itself
The most expensive part of onboarding isn't sending the request. It's the follow-up — the reminders, the "just checking in on those documents," the mental load of remembering who owes you what. Multiply that across every new client and the chasing becomes a job in itself.
This is exactly the work that accounting client management software should take off your desk. In Finye, the combined onboarding request goes out through the client portal with its outstanding items tracked as a live checklist. The client sees what's still needed; the system sends the reminders on a schedule; and the file simply won't tip into "ready to work" until both the verification and the documents are complete. Your team isn't manually cross-referencing two separate to-do lists — the status reflects reality.
Because Finye keeps the client record as the single source of truth — not your ledger — the verification details and returned documents live against the client, ready for the engagement letter, the job and the sync to Xero. You're not re-keying the ABN into three systems or wondering whether KYC was ever finished.
What good looks like
A well-run combined sequence produces a simple, honest picture:
- Every new client gets the same onboarding request, tailored to their service, sent once.
- Verification and documents are tracked as one gate, not two.
- Reminders go out automatically; nobody carries the chase in their head.
- A job shows "ready" only when it genuinely is.
- There's a clean, retrievable record of what was verified and received.
None of this requires a tax return software or a lodgment tool. It's practice management — running the firm around the work rather than the work itself. Get the onboarding sequence right and you remove the most common reason new engagements stall before they start: the file that looks open but is quietly waiting on something you never finished asking for.