AML/KYC client onboarding for accountants
A step-by-step AML/KYC client onboarding process for accountants and tax agents: verify identity, collect documents, assess risk and keep the evidence on file — all inside Finye.
Bringing on a new client means more than creating a record and sending an engagement letter. As a tax agent or accountant you have obligations to know who you are acting for, confirm their identity and keep evidence of the checks you carried out. Finye's AML/KYC onboarding ties this work to the client record so the verification, documents and risk notes all live in one place rather than scattered across emails and a shared drive.
This guide walks through the AML/KYC client onboarding process end to end, from raising the request to recording the outcome. It assumes the client already exists in Finye, or that you are creating them as part of the process.
What is AML/KYC client onboarding?
AML (anti-money-laundering) and KYC (know your customer) onboarding is the set of checks a practice runs before it starts acting for a new client. In plain terms it answers three questions: who is this client, have you confirmed they are who they say they are, and what is the risk of acting for them? For an accounting or bookkeeping firm that means collecting identity evidence for each relevant person, checking it against the details on file, assigning a risk rating and keeping a durable record of the whole thing. Doing AML client onboarding well protects the practice, satisfies your professional obligations and gives you a clean audit trail if you are ever asked to show your work.
Before you start
AML/KYC onboarding works alongside the rest of the client file. The identity documents you collect become part of the client's document and PBC requests, and the verified client can then move straight into engagement letters and recurring work. It helps to decide in advance which documents you require for each entity type, because an individual sole trader and a company with several directors need different evidence.
The AML/KYC onboarding process, step by step
- Open the client and start onboarding. Go to the client record and open the AML/KYC onboarding section. If you are acting for a new organisation, set the entity type first (company, trust, partnership, sole trader or SMSF), because the people you need to verify depend on the structure.
- Identify the people to verify. Confirm the contacts attached to the client and mark who needs identity verification. For a company this is typically the directors and any beneficial owners; for a trust the trustees and beneficiaries; for a sole trader the individual. Add any missing contacts so each person who needs checking has a record.
- Request the identity documents. Raise a document request for each person, asking for the evidence you require. Common items are a current passport or driver licence, proof of address, and entity documents such as a company extract or trust deed. The client receives the request and uploads the files through the client portal, so nothing arrives as a loose email attachment.
- Review what comes back. As documents are uploaded, check each one against the person and the details on file. Confirm names, dates of birth and addresses match, and that the documents are current and legible. If something is missing or unclear, send the request back with a note rather than accepting incomplete evidence.
- Record the verification outcome. Mark each person as verified once you are satisfied, and note the method you used and the date. This creates the evidence trail that shows the check was performed, by whom and when.
- Assess and record risk. Capture a risk rating for the client based on the entity type, the nature of the work and any factors that warrant closer attention. Keep a short note explaining the rating so the reasoning is clear to anyone who reviews the file later.
- Complete onboarding. Once every required person is verified, the documents are held and the risk is recorded, mark the onboarding as complete. The client is now ready for engagement letters, compliance obligations and ongoing work.
KYC for accountants: what to collect
KYC for accountants comes down to holding enough evidence to be confident of each person's identity and role, matched to the client's structure. As a practical starting point:
- Every individual you verify — one primary photo identity document (current passport or driver licence) and one proof of address (a recent utility bill, bank statement or rates notice).
- Companies — a current company extract, plus identity evidence for each director and beneficial owner.
- Trusts — the trust deed, plus identity evidence for the trustees (and appointors or beneficiaries where relevant).
- Partnerships — the partnership agreement where available, plus identity evidence for each partner.
- SMSFs — the fund's governing documents, plus identity evidence for the individual or corporate trustees and members.
Collect the same core items for every client so the file is consistent, and note your risk rating and reasoning alongside the evidence rather than in a separate spreadsheet.
Working with different entity types
The amount of verification depends on the structure, so it is worth knowing what to expect.
Individuals and sole traders
You are verifying one person. Collect photo identity and proof of address, confirm the details and record the outcome. This is the quickest path and a good way to get familiar with the flow.
Companies, trusts and partnerships
These involve several people. For a company, verify the directors and beneficial owners and hold the company extract. For a trust, verify the trustees and capture the trust deed. For a partnership, verify the partners. Add every relevant contact before you start so no one is missed, and verify each person individually.
SMSFs
Self managed super funds usually have individual or corporate trustees plus members. Verify the trustees and members and hold the fund's governing documents alongside the identity evidence.
AML client onboarding checklist
Use this short checklist to confirm an onboarding is genuinely complete before you start work:
- Entity type set and the correct people identified for verification.
- A document request raised for each person and returned through the portal.
- Every document checked against the person and the details on file.
- Each person marked verified, with the method and date recorded.
- A risk rating captured, with a short note explaining it.
- Onboarding marked complete so the client is cleared for engagement letters and work.
Keeping the trail clean
The value of doing this inside Finye is the record it leaves. Because the documents, verification outcomes and risk notes are attached to the client, you can see at a glance who has been checked, what evidence supports it and when it was done. If you are ever asked to demonstrate that you met your obligations, the evidence is on the file rather than reconstructed after the fact.
A few habits keep things tidy:
- Verify people as documents arrive rather than in a single rushed batch later.
- Write a short note with each risk rating so the reasoning survives staff changes.
- Re-run onboarding when a client's structure changes, such as a new director or trustee, so the file stays current.
After onboarding
With the client verified, the rest of the practice work flows naturally. You can issue an engagement letter and have it e-signed, set up the recurring lodgment obligations the client needs, and begin raising work items. The document requests you used for identity evidence are the same tool you will use throughout the relationship to collect records for each job, so the onboarding work pays off well beyond the first week.
For more on the surrounding workflow, see the rest of the complete guide to Finye, which covers document requests, engagement letters and compliance obligations in detail.