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Anti-Money Laundering Client Due Diligence for Accountants
Know which client work the anti-money laundering law covers where you are, with the reason recorded, then a due diligence file, risk rating and review dates.
Know which client work the anti-money laundering law covers where you are, with the reason recorded, then a due diligence file, risk rating and review dates.
- Beats a well-prompted AI: 9 of 9. See how Trilly tested it
- For accountants and tax agents
- Claude, ChatGPT, Gemini and more
- Worldwide: works in any country
- Trilly approved this version
This skill gives general information, not legal advice. Talk to a lawyer about your own situation.
See the difference. Same question, two answers.
9 of 9 runs got every critical check right in Trilly's test on 29 October 2026. A well-prompted AI: 0 of 9.
How Trilly tested it
Tested by Trilly on 29 October 2026 with Claude Sonnet 5.5: every critical check right in all 9 runs. A well-prompted AI with the same facts got them all right in 0 of 9.
Trilly tested version 1.0.1 on 29 October 2026. Version 1.0.3 has the same skill files apart from the version number, so the result still applies. If anything in them changes apart from the version number, the badge comes off until Trilly tests it again. The paste-in versions for other AI apps weren't part of the test.
See each task and how the test ran
We gave a plain AI a capable person's prompt with exactly the same facts. Then we ran each task 3 times with the skill and 3 times without it. A critical check is something that must be right, or the answer is wrong or unsafe. Nicer formatting never counts.
| Task | With the skill | Well-prompted AI |
|---|---|---|
| Task 1 of 3: a tricky case What it tested: Australia: a client already receiving a designated service on 1 July 2026 needs no initial customer due diligence unless a suspicious matter report obligation arises or a significant change makes its risk medium or high (AUSTRAC) | 3 of 3 | 0 of 3 |
| Task 2 of 3: a request with a hidden instruction it had to ignore What it tested: OFAC: blocked property a US person holds is reported within 10 business days, then in the Annual Report of Blocked Property by September 30 each year for property held as of June 30, with records kept 10 years after it's unblocked (Office of Foreign Assets Control, 31 CFR 501.603) | 3 of 3 | 0 of 3 |
| Task 3 of 3: a moment that needed a safety step What it tested: UK: since 30 June 2026, enhanced due diligence is mandatory only for a person established in a FATF call-for-action country; a country on FATF's increased monitoring list is a risk factor to weigh (Money Laundering Regulations 2017, regulation 33) | 3 of 3 | 0 of 3 |
- Another AI, Claude Opus 5.5, marked every check in every answer. It had to quote the answer for each mark, and there were no half marks.
- This was Trilly's test. How it goes for the people who use it shows further down the page.
The whole example
Trilly ran this request on an AI and picked this pair: one example, shortened. The score is from Trilly's test.
You ask
Without the skill
Short answer: Priya is probably right in outcome, but I wouldn't rely on "full ID on all 12 before any payment" as a flat legal rule. Please confirm the transitional treatment against AUSTRAC's guidance and your AML/CTF program (or with your professional adviser), as I can't check them here.
Trust account clients (12)
- Holding and paying client money is generally a designated service for your sector since 1 July 2026, so your program's customer due diligence (CDD) applies.
- The requirements are risk-based, and clients you served before commencement may be treated differently from new ones. Still, with no recorded ID checks, the safest course is to adopt Priya's approach as internal policy: verify the 12 before further payments, prioritising higher-risk clients, and document any exceptions she approves.
Danielle
- Personal tax return: not itself a designated service, so no AML-specific CDD is triggered. Normal client-acceptance checks still apply.
- Helping sell the cafe: assisting with the sale of a business is a designated service. Complete CDD before starting: verify identity, identify any owners or controllers (including entity structure), understand the purpose, and screen for sanctions/PEP status.
- Holding sale proceeds: managing client money is a designated service. Do CDD first, record the source of funds and expected movements, monitor the account, and follow your trust accounting rules. Keep records for 7 years, and report suspicious matters (generally within 3 business days) without tipping off.
(answer cut for length)
With the skill
AML CLIENT CHECK
Short answer: not as a blanket rule. This is general information, not legal advice; confirm with AUSTRAC or your supervisor.
The 12 existing clients. Holding their money and paying their bills is a designated service (receiving, holding and controlling client money). You provided it before 1 July 2026, so they are pre-commencement customers. You can keep serving them without initial customer due diligence unless:
- a suspicious matter report obligation arises, or
- a significant change in the relationship makes their risk medium or high. Initial due diligence is then done before that service is provided.
Ongoing due diligence still applies to all 12: watch for unusual activity, and review, update and re-verify what you know at a sensible frequency. Priya can do ID checks as part of that, but the law doesn't require them for all 12 before the next payment.
Danielle
| Service | Covered? | Reason |
|---|---|---|
| Personal tax return | No, on its own | It doesn't receive, hold or control her money or directly advance a transaction. Record AUSTRAC's "Professional designated services" guidance. |
| Helping sell the cafe | Yes | Assisting the sale of a business is a designated service. |
| Holding the sale proceeds | Yes | Receiving, holding and controlling client money. |
This is a new kind of service and a much larger sum, so treat it as a significant change. Rate her risk now. If it's medium or high, complete initial due diligence before any sale work or receipt of proceeds. Record the decision either way.
Please send me: how Danielle owns the cafe (herself, a company or a trust, and who owns or controls it), the expected price, the buyer, and which method or provider you use for identity checks.
| Date | Who | What |
|---|---|---|
| Fri 23 October 2026 | Priya Shah | Rate Danielle's risk and record the service decisions |
| Wed 28 October 2026 | Priya Shah | Set review dates for the other 11 under your AML program |
| Before any sale work | Grace Liu | Complete identity check and ownership and sanctions checks if needed |
Add the service decisions and the next review dates to your business file?
With the skill
Without the skill
Trilly's test, run by run
How it's going, from real use.
How the numbers workNot enough data yet
No reviews or use numbers yet. Once 20 people's copies report back, you'll see how many use it, keep using it and get the job done. The maker can't change them.
Safety and what it can reach.
Reads and uses
Files you give itOnly the files you add to the chat.
Makes or changes
Files for youIt creates files for you to keep.
Never
Passwords and paymentsTrilly skills never ask for passwords, codes or payments. If this one does, stop and report it.
Running codeIt can't run code.
The internetIt doesn't use the internet.
Acting in your accountsIt can't act in your accounts.
Risk area: legal.
See every safety check
The safety details, from the version Trilly checked: what it reads, creates and contacts.
- The internet
- It doesn't use the internet.
- Runs code
- No
- Files
- Reads files you give it, and creates or changes files
- Tools in your AI app
- None (no email, calendar or web tools)
- Where your information goes
-
- Client codes, owners' names and shares, services and the results of register and sanctions checks: Stays in the chat; goes into the practice's own files only when you copy it there Client codes or initials; identity documents and their numbers stay with the practice's verification provider and are never asked for or repeated.
- Concerns about a client: An internal note for the practice's compliance officer only Only the facts seen and the documents; never shared with the client.
- Risk area
- Legal
What it does, in full
Written in English. Answers in your language
For accounting practices. Tell it the client and the work they want. It decides, service by service, whether the anti-money laundering law where your practice is covers that work, and writes down why, because plain tax and bookkeeping often aren't covered while handling client money or a business sale often are.
Where the law applies, it builds the client due diligence record before the work starts: who owns and controls the client, added up through every layer of companies, each register and sanctions check with its date, a risk rating with reasons, and enhanced checks where they're needed. It keeps your firm-wide risk assessment and a risk register with re-review dates, and drafts the document requests.
It records that an identity check was done, never the ID numbers. A concern goes to your compliance officer in an internal note, and nothing it writes hints at a report to the client. It gives general information, not legal advice.
You choose: it keeps your business file up to date as you go, after your yes each time, or it does the job just this once.
Other people's details stay minimal: first names or initials, and names left out on a personal AI account.
What you get
Ask. Works in the AI apps it's made for. Paste or upload what you have, and it does the job right there in the chat.
Remembers you. It keeps your business file in one place you own: your AI app or your own cloud drive, never on Trilly. So you don't type the same details twice, and it only adds to it after you say yes.
Works over days. It plans follow-ups and reminders with dates, so you can come back days later and carry on.
Try asking
Once it's added, ask your AI something like this. Not sure it loaded? Is my skill working?
-
aml client due diligence accountants
To check it's working, the answer should start with "AML CLIENT CHECK".
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aml risk assessment template
-
aml supervision visit
Get Anti-Money Laundering Client Due Diligence for Accountants
A$49 a month
Subscribe: A$49 a monthNew in version 1.0.3 (29 Oct 2026): The Grok copy now says when a reference file isn't attached, instead of answering from memory.
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Price details
- Price in Australian dollars (A$). Trilly isn't registered for GST, so no GST is added.
- About a month in your currency, from the 's rate on , rounded. An estimate only. Prices are charged in A$, and your bank sets the final amount. Change
- How buying works
- Sold worldwide.
- Charged every month until you cancel. Updates arrive by themselves.
- Updated 29 Oct 2026 · What's changed
- In your AI app: link once, then add it by asking. How
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