From 1 July 2026, Pilot Partners must comply with the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (the Act). This change has been implemented across the accounting and legal professions and means that we have legal obligations to verify the identity of our clients and carry out background checks.

This not only applies to new clients, but also to continuing clients where we are engaged to provide Designated Services (see below). Thus, although we may have known you for many years, we might still have to ask you identity verification questions before assisting with certain work going forward.

How the AML/CTF changes may affect you

Before we can provide Designated Services (see below), we are required by law to:

• Verify that you are who you say you are (check your identification), and that you are authorised to act on behalf of another entity (if applicable)
• Trace through any relevant business and personal structures to confirm the individuals involved (e.g. directors, shareholders, appointors, beneficiaries etc)
• Attend to identification processes for those underlying individuals as well
• Check whether any individual (including yourself) appears on any sanctions or Politically Exposed Persons lists
• Check the source of funds and wealth

To satisfy these requirements:

• Our team may ask you additional questions and request various documentation before we can proceed with a new service or engagement. This may include obtaining structure documents such as constitutions, trust deeds, company searches etc where we do not already have these on our files.
• You, and perhaps other persons in your family or business group, may be required to complete identity verification processes. This verification will be done through our third-party secure provider, and will typically require you to answer some questions and upload photo ID.

This verification process may cause delays in starting work, and therefore it may take longer to attend to the services required. Where time is critical, it will help keep things moving if you have identification and relevant structure documents readily available. Providing these with your request for services will help us fast-track our checks here, and we will work with you as best we can to get things processed in a timely manner.

When AML/CTF requirements apply to you

This applies to all new designated services provided from 1 July 2026. Thus, while it certainly applies to all new clients going forward, it also applies if you are an existing client.

Therefore, if you request new services or extend our engagement scope at some point, we may need to attend to these verification checks depending on the work to be provided.

We also have an obligation to monitor existing client relationships, and regularly assess when it might be appropriate to attend to certain integrity checks. As such, you may still hear from us regarding extra verification or checks throughout our ongoing engagement with you, even without any changes to our services.

What are the Designated Services?

Designated Services are defined by the Act and include:

• Registered office services
• Acting as a director
• Having authority over your bank account to make payments (including joint authority)
• Assisting in setting up a company or superannuation fund
• Drafting or reviewing trust deeds
• Reviewing contracts for sale of real estate
• Providing services relating to a company sale, restructure, or merger/demerger (due diligence, negotiations, valuations, agreements/documentation, shareholder agreements etc)
• Assisting in financing or securing equity, including negotiating, structuring, or documenting (this includes Division 7A loans)

We note that the above list is not exhaustive.