Client-pays KYC in Australia

Lead with the client, not the seat

Principals are not losing instructions because they failed to mention a feature grid. They are losing them when AML shows up as a new monthly cost, a vague “compliance levy”, or a surprise line after the authority is signed. The firms that sound calm describe one thing: customer due diligence on this matter, paid by the client, recorded by the firm.

“Client pays KYC Australia” is a thin search. It is a loud conversation: in agency meetings, in costs agreements, and in property threads about who pays the verification. This page is that conversation. The legal-and-disclosure version is can you charge the client for an AML check?.

Client-pays and pay-as-you-go answer different questions

Pay-as-you-go means the firm can buy checks without a monthly AML subscription. The firm might still be the payer. Client-pays means the client’s card covers the verification, so the firm’s cash for that check can be zero. Both can be true on FreeAML. They are not the same sentence in a pitch. The pricing-model page is pay-as-you-go AML and KYC.

Why principals put it in the first email

• It matches disbursements clients already accept: title searches, certificates, identity work on a conveyance.
• A quiet month does not create a software bill the firm has to justify.
• The quote for the matter can be explained without a spreadsheet of seats.
• The client hears a professional reason, tied to the service you are providing, rather than a software upsell.

Competitors describe the same pressure with different mechanics. AML Guard’s pricing article explains a customer-pays path that credits the agency’s subscription, capped at the licence fee. That still assumes a licence. ClearAML and easyAML publish their own plan pages; read those pages for their current shape. Flagship’s comparison is a third-party view. FreeAML’s position is narrower and easier to say: A$0 firm suite, client-pays verification. Current amounts are on /pricing.

Words you can send

Put this in the engagement email, in your voice. FreeAML sends the verification request by email, so this note and the request match.

Longer scripts and objection handling are in how to talk about AML with clients.

What that paragraph leaves with you

• Enrolment with AUSTRAC, on AUSTRAC’s site.
• The written program and the ML/TF risk assessment. A starting point on this site is /risk-assessment.
• Who the customer is on this file, including beneficial owners.
• The risk rating and the decision to proceed.
• Suspicious matter reporting, if you form a suspicion. The client-pays sentence is not a script for that moment.

A week-one commercial setup

1. Add two sentences to the agency agreement, costs agreement, or engagement letter: what the check is, and that the client pays the verification.
2. Point staff at one internal example, not a new policy novel.
3. Send the first in-scope matter from /aml-check with client-pays.
4. File the outcome next to the risk note.
5. Review the first five invoices for wording. If a client read “government fee”, change the template that day.

If the debate in your firm is “what should free software include, and what is the paid check?”, read what a free AML tool should include. If the debate is “is our old identity process enough?”, read VOI and CDD.

Frequently Asked Questions