The Same Documents, Requested Twice: PBC Meets AML
Most firms treat proof-of-identity and PBC lists as two separate chores. Combine them into one onboarding request and you'll collect more, faster, with a cleaner audit trail.
Think about how a new client actually experiences their first fortnight with your firm. They sign your engagement letter. A day later, an email lands asking for a copy of their driver's licence and passport for identity verification. A few days after that, another email arrives with a prepared-by-client (PBC) list: bank statements, loan documents, the prior year's financials, motor vehicle logbooks, and a dozen other items.
Two requests. Two threads. Two opportunities for the client to reply to one and forget the other. And for you, two separate places to track what's come back and what hasn't.
The information you need for anti-money-laundering (AML) and know-your-customer (KYC) checks and the information you need to start the actual work aren't really two jobs. They're two halves of the same moment: the client is engaged, motivated, and paying attention. That's the moment to ask once.
Why firms split what should be one request
The separation is usually accidental. KYC lives with whoever handles compliance and onboarding. The PBC list lives with the accountant who'll do the return or the annual accounts. They use different tools — an ID-verification portal here, a spreadsheet or email template there — and the two never meet.
The cost of that split is real:
- Client fatigue. Two rounds of requests feel like twice the friction. Clients who would happily upload six documents in one sitting quietly deprioritise the second email.
- Follow-up doubles. You're now chasing two lists, sometimes with two different people in the firm chasing the same client for related things.
- The audit trail fragments. When AUSTRAC obligations tighten and tranche-two reforms bring more accounting services into scope, you want a single, timestamped record of what you asked for, when, and what the client provided. Two systems make that a reconstruction exercise.
The case for a single onboarding request
When you combine identity verification and the PBC list into one structured request, three things improve at once.
Completion rates go up
A client who's already opening documents to photograph their licence is in the right headspace to also grab a bank statement. Batching the ask captures that momentum instead of fragmenting it across a week of separate emails.
Your team stops working from two lists
One checklist, one status view. You can see at a glance that a client has provided ID and three of five PBC items — rather than cross-referencing a verification tool against a spreadsheet to work out where they're stuck.
The compliance record is coherent
Good client accounting depends on being able to show your working — not just on the tax return itself, but on how the client came to be your client in the first place. A single onboarding record that captures identity documents, source-of-funds context where relevant, and the engagement documents belongs together, not scattered across inboxes.
What a combined request actually looks like
The point isn't to blur AML and PBC into an undifferentiated pile. Identity verification has its own requirements — you still need to sight and verify documents to the standard your risk assessment demands. The point is that the client shouldn't have to notice they're two workflows. They see one clear list; you see the compliance items and the work items separated on your side.
A practical structure:
- Identity and verification. Photo ID, secondary identification, and for entity clients, evidence of beneficial ownership and the right to act. Flag these as mandatory before any work begins.
- Entity and registration details. ABN, ACN, TFN references, and confirmation of the entity structure — the details that need to be accurate and consistent across every system you run, from your practice records to Xero.
- PBC items for the engagement. The specific documents tied to the work you've been engaged for — financials, statements, logbooks, prior returns.
Present them as one journey with clear sections. The client uploads everything through a single front door and never has to guess whether they've done enough.
Where the software earns its place
This is exactly the kind of problem that accounting client management software is meant to solve — and where good account practice management software differs from stitching together an ID tool, a spreadsheet, and your email.
In Finye, onboarding runs from one templated request. When you engage a client, the same step that sends the engagement letter for e-signing can trigger a combined PBC and AML checklist through the client portal. The client logs in once, sees everything you need, and uploads it in one place. On your side, the identity items and the work documents track separately but sit under the one client record.
Because it's part of your practice management system rather than a bolt-on, a few things follow naturally:
- Outstanding items are visible on the client's onboarding work item — no separate spreadsheet to reconcile.
- Reminders for anything not yet supplied go out automatically, so nobody on your team is manually chasing two lists.
- Entity details captured at onboarding — ABN, ACN, contact records — flow into your two-way Xero sync accurately, rather than being re-keyed and duplicated later.
- The whole trail is timestamped and stored against the client, so if your onboarding is ever reviewed, the record is already assembled.
Finye isn't a tax return software tool and it doesn't do your ledger — it runs the practice around the work. Onboarding is where that distinction matters most: the software's job is to make sure the right documents and verifications arrive, completely and on time, so the lodgment and accounts work can actually start.
Start with the first request you send
If your firm currently sends KYC and PBC as two separate messages, that's the single change worth making this quarter. Draft one onboarding request that covers both. Map which items are verification, which are entity details, and which are engagement-specific. Then make it a template so every new client gets the same complete ask, the first time.
Clients notice when onboarding feels considered rather than piecemeal. Your team notices when there's one list to work instead of two. And when your obligations are reviewed, you'll have one clean record instead of a reconstruction. Asking once is better for everyone — including the version of you who has to chase the gaps later.