Trigger events to refresh KYC on a long-term accounting client

People search “refresh KYC existing accounting client” when a suburban tax practice has lodged the same company’s returns for years and a new director has just appeared on the ASIC extract. Checked against AUSTRAC’s page on reviewing KYC information on 4 October 2026. This is general information, not legal advice. This page does not reproduce that guidance. The one-time move of clients who were already on the books when obligations started is pre-commencement customers. Day-to-day monitoring after that is ongoing customer due diligence for a small firm. The sector map is /tranche-2.

What counts as a trigger on a tax file

A long-term accounting client feels known, which is how a refresh gets skipped. The program should name the events that make the old KYC information unreliable. Those events are about the customer and the service, not about the firm’s software renewal. A Parramatta practice that only refreshes when the engagement letter is reprinted will miss a director change in March.

• Control changed. A new director, a new trustee, or a shareholder who now meets the ownership or control test is a reason to identify that person.
• The service changed. The annual return is not the same job as acting on a sale of the company, if that sale is a designated service in the program.
• The risk changed. A PEP match, a sanctions concern, or behaviour that no longer fits the file moves the review forward.
• The review date fell due. The program’s own cycle for that risk rating is a trigger even when nothing dramatic happened.

Same client, different reason to open the file

Staff need a sort they can use on a Friday afternoon. The question is which event happened, and whether the program already named it. A hunch that the client feels different is a prompt to look at the program, not a private rule.

Where the refresh page stops

This page is the trigger on an existing accounting relationship. It is not the one-time transition of pre-commencement customers, and it is not the whole monitoring duty. Those sit on pre-commencement customers and ongoing customer due diligence for a small firm.

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. A diary reminder to review a file is not a check, and the firm suite does not include one. Confirm the live amounts on FreeAML pricing. FreeAML does not decide which trigger applies to a client, or refresh a file the program does not require.

Frequently Asked Questions