Disbursement versus professional fee for an AML check

People search “disburse AML cost” when a two-partner firm is about to drop the check into disbursements on the tax invoice. Checked against AUSTRAC’s summary of Tranche 2 obligations on 4 October 2026. This is general information, not legal advice. This page does not reproduce that guidance. Whether a firm may have the client pay is can you charge the client for an AML check. The client-pays model itself is client-pays KYC in Australia. The sector map is /tranche-2.

Three labels, one of them fits

Law firm billing has a small set of honest labels, and a professional fee is the firm’s charge for work. A disbursement is a cost the firm paid to someone else and recovers. A client-pays verification is neither, because the firm never paid it, and the client pays FreeAML. Putting A$20 or A$40 in the disbursement column invents a cost the firm did not incur.

The compliance obligation is still the firm’s, and AUSTRAC does not invoice the check. How you tell the client about the price is a billing conversation, on top of the program. This page is that label. It is not a ruling on goods and services tax, and it does not tell you how to word a costs agreement clause by clause.

• Do not disburse a cost you did not pay. If the receipt is in the client’s name, it is not a firm disbursement.
• Do not call it professional time. The lawyer’s time spent reviewing the result can be a fee. The check price itself is the verifier’s charge.
• Say who is paid. The engagement note can say the client pays the verifier at the list price. The firm suite is A$0.
• Match the entity. A person is KYC. A company or a trust is KYB. The bill, if you mention the figure, uses that split.

Where the amount sits

What firms spend across a year is a different question, on AML compliance cost in Australia. This page stays with the invoice label.

Where the billing-label page stops

This page is disbursement versus professional fee versus client-pays. It is not tax advice and it is not the costs agreement. FreeAML does not draft your bill or decide that the matter is a designated service.

What the client pays

On FreeAML the firm suite is A$0. The firm emails the client a link. Verification is client-pays. On the public list a personal KYC check is A$20 and a company or trust KYB check is A$40. Use KYB when the customer is a company or a trust. There is no firm cost to put in the disbursement column, because the client pays the list price to the verifier. Confirm the live amounts on FreeAML pricing. FreeAML does not describe the check as your professional fee or as a disbursement you incurred.

Frequently Asked Questions