Do not collect source of funds on every low-risk file

People search “source of funds not always required” when a two-partner firm has started asking every client where the money came from, including files the program rated low. Checked against AUSTRAC’s enhanced customer due diligence guidance on 4 October 2026. This is general information, not legal advice. This page does not reproduce that guidance. What enhanced due diligence is for is enhanced customer due diligence in Australia. The standard measures are customer due diligence requirements. The sector map is /tranche-2.

Low risk has a shorter list

The point of a risk rating is that the measures change, and a low-risk file in a two-partner firm takes the standard measures the program set for that rating. Source of funds is information about where the money for the matter came from. AUSTRAC treats that kind of enquiry as something you add when the risk is higher, not as a form you staple to every file so the drawer looks full. This page does not reproduce the enhanced due diligence guidance, and it does not invent a document pack.

The opposite mistake is real, and a file you have already called high, or a file with a third party paying the price, is not kept on the low-risk list out of habit. The phrase source of funds not always required means not always. It does not mean never. The program is the switch.

• Read the rating before you add questions. A low rating uses the low-risk measures. Do not borrow the high-risk list to feel safer.
• Name the trigger that moved the file. Third-party funds, a PEP, a country factor, or an unusual pattern are the usual reasons a program asks for source of funds.
• Record a decision not to ask. On a low-risk file, a line that source of funds was not required by the program is a better note than a blank questionnaire.
• Do not swap it for identity. Knowing where money came from does not identify the customer. The KYC or KYB check the program requires is still the check.

When the extra question belongs

The overview of customer due diligence, without this source-of-funds point, is AUSTRAC customer due diligence. Keep that page for the whole CDD shape.

Where the source-of-funds page stops

This page is when source of funds is not the default. It is not the enhanced due diligence procedure and it is not a list of bank records to demand. FreeAML does not rate the file.

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 source-of-funds question is not a separate list price, and it does not replace the client-pays KYC or KYB check the program already requires. Confirm the live amounts on FreeAML pricing. FreeAML does not decide that this file needs source of funds or add it to every low-risk matter.

Frequently Asked Questions