Documents that count
- Individuals: Australian driver licence, passport, or other government photo ID. Certified copies are acceptable when the client is not met in person.
- Companies: a current ASIC company extract, plus identification of directors and beneficial owners.
- Trusts: the trust deed (or relevant extracts), plus identification of trustees and beneficiaries or classes of beneficiaries.
- Partnerships: the partnership agreement and identification of partners.
Meeting in person or not
Face-to-face verification is simplest: sight the original, note the details. Clients you never meet need either certified copies or an electronic identity verification service. Not meeting face to face is itself a risk factor that should push the rating up a notch.
What to record
- Document type and number (store the number, not necessarily a scan; if you keep scans, secure them).
- Who verified it and the date.
- The risk rating and the reasons for it.
- The purpose of the relationship.
- The next review date.
Keep it for 7 years
Identification records must be kept for 7 years after the relationship ends. Never delete a client file; archive it.
Questions people ask
- Is a scanned licence emailed by the client enough?
- On its own, no. An uncertified scan is not a reliable and independent verification. Use certified copies, an electronic verification service, or sight the original.
- Do I have to keep a copy of the ID?
- You must keep a record of the identification carried out. Recording the document details is the minimum; keeping copies is common but brings privacy obligations.
This guide is general information for accountants, bookkeepers, BAS agents, not legal advice. Check AUSTRAC's current guidance for your situation.