09/06/2026
【Why Is Your Accountant Suddenly Asking Where Your Money Came From?】
Over the past few months, we have been hearing the same questions from clients:
“Will it become harder to transfer money from overseas into Australia?”
“If my parents gift me money, or I invest overseas funds into Australia, will I be asked for more documentation?”
The short answer is:
Legitimate funds and normal transactions are not the problem. However, being able to explain the source of funds will become increasingly important.
From 1 July 2026, Australia’s new Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) reforms will come into effect.
The changes don’t just affect banks.
Accountants, lawyers, real estate agents, conveyancers and other professional service providers will also be required to conduct additional identity verification and source-of-funds checks.
This means that if you are:
✔ Receiving overseas funds
✔ Purchasing property
✔ Establishing a company or trust
✔ Bringing in investors
✔ Undertaking business acquisitions
You may be asked to provide more supporting documentation than before.
What should individuals be aware of?
If you are involved in:
• Overseas transfers into Australia
• Parental gifts for property purchases
• Overseas investment funds
• Trust-owned assets
• Commercial property transactions
Consider keeping copies of:
✓ Bank statements
✓ Transfer records
✓ Gift letters
✓ Loan agreements
✓ Sale and purchase contracts
These documents may become important evidence of the source of your funds.
What should business owners be aware of?
For SMEs, the focus will increasingly be on financial transparency.
Activities such as:
• Company formation
• Share transfers
• Bringing in investors
• Business acquisitions
• Trust restructuring
may require additional information, including:
✓ Shareholding structure charts
✓ Trust structure diagrams
✓ Beneficial ownership information
✓ Source of investment funds
✓ Explanation of fund flows
Businesses involving overseas investors, overseas shareholders, Family Trusts or Unit Trusts may face more frequent due diligence reviews.
What should you do now?
My recommendation is simple:
Start building your own “Source of Funds File” today.
Keep records of:
✓ Large transfers
✓ Overseas remittances
✓ Gift documentation
✓ Loan agreements
✓ Investment contracts
✓ Share transfer documents
✓ Trust deeds and trust records
In the future, compliance will not only be about lodging tax returns.
You may also need to clearly explain:
Where did the money come from? Why was it transferred? Who ultimately controls it?
Good record-keeping today can save significant delays, questions and stress later when dealing with banks, accountants, lawyers and regulators.
The businesses and individuals who prepare early will be in a much stronger position when these new rules take effect.