industry
Extract client documents into checkable registers.
The IESBA Code of Ethics for accountants already covers AI. Since December 2024, it has asked accountants to judge whether a tool's output is fit for purpose, including its limits, data quality and bias, and to guard against automation bias. In 2026, IESBA put it plainly: professional responsibility can't be delegated to a machine. The FATF Recommendations put due-diligence and record-keeping duties on accountants for some client work, such as setting up or managing companies and trusts. We build registers and drafts that a person approves, and we never make the due-diligence decision. Your own regulator's rules always come first.
Which rules apply to you is your compliance or legal team's call. We map our evidence to them; we don't certify against them.
In Australia, more than a million trusts appear in the ATO's 2023–24 trust return statistics. Seniors read each client's deeds by hand, again every year end.
One register of every client trust, each field linked to its page and checked against deeds your seniors already know.
ATO, Trust statistics for Taxation statistics 2023–24, as at
Trust Deed & Client Structure Register
Trust roles for AML/CTF due diligence
Only if your practice provides services under AML/CTF rules, such as AUSTRAC-regulated services in Australia.
Admin Hours Audit + Switch-On
ATO Letter Sorter Australia
Ask the Firm Manual
For larger practices.
Sources
Lead solutions
Every trust deed and deed of variation in your client book, read into one register: trustee, appointor, beneficiary classes, vesting date and amendment history, with streaming and distribution clauses flagged for partner attention.
The Admin Hours Audit takes 1 week and maps where staff hours go. Switch-On takes 2–3 weeks: it configures features you already own; for firms in Australia, it applies the relevant Safe-Use Kit as published, where one has been published; and it trains staff and measures the hours saved at day 30.
Reads each ATO letter for the action and due date, matches it to the right job and drafts the reply for a person to approve, for practices without an ATO document feed.
Run Karbon? Its email summaries and suggested replies are on by default. In Australia, on FYI, look at its ATO SmartDocs integration for tax-office documents. For one client's due diligence, First AML's AI document reader reads trust deeds inside the case.
Illustrative scenario: not a client engagement
Problem
At a fictional practice of about 120 staff, seniors reopen several hundred client trust deeds each June.
Approach
Two seniors record answers for 40 deeds they know. The register reads those deeds, links every value to its page and queues anything unsigned.
How we'd measure
What ships first
The Two-Week Trial report: the error rate for each field, and a go/no-go.
At the go/no-go, you decide whether to continue. If you stop, you keep the trial report, the answer key and the rows produced.
Australia is our home market and the one we know best.
Works alongside
| Obligation | What it means for an AI system | How we design for it | Evidence you get | Source |
|---|---|---|---|---|
| TASA s 30-10 Code item 6; TPB(GS) 55/2026 ¶¶23–25: client permission before AI use | Entering client information into an AI tool can be a disclosure to a third party, depending on how the tool is configured and used, so client permission may be needed first. | A data note says which providers see client data and where it's processed. | A one-page data note naming each processor, its region and its retention setting | Source, as at 22 July 2026 |
| APESB Technical Alert (31 Oct 2025): APES 110 applies to AI use | Members using AI must keep meeting APES 110 and critically assess and verify AI-generated information, and the APESB says they should disclose and supervise AI use. | Every register field links to its page, so a reviewer can check it. | A register with a source-page link per field, and a test report listing every miss | Source, as at 31 October 2025 |
| Privacy (Tax File Number) Rule 2015 ss 10, 11: use limits and safeguards for TFNs | Every holder of TFN information, whatever its size, may use or disclose it only for tax, superannuation or personal-assistance law purposes (or to give individuals their own TFN information), and must take reasonable steps to protect it. | TFNs are masked before any model call unless the job needs the field. | A masking test result that lists any TFN left unmasked | Source, as at 4 March 2015 |
| Privacy Act APPs 6 and 11: personal information entered into AI products | For practices the APPs cover (generally turnover over $3m; smaller ones only in listed cases), putting personal information into an AI product is a use or disclosure under APP 6, and APP 11 requires reasonable security steps. | Where the provider offers the setting, tools are set so it doesn't train on what you enter. | A region note stating where inference runs and what the provider retains | Source, as at 17 January 2025 |
| AML/CTF Act s 28 (from 1 Jul 2026 for table 6 services): initial CDD for a trust customer | A practice providing AUSTRAC-regulated services, such as setting up or restructuring a trust, must establish a trust customer's trustees, beneficiaries or their classes, and beneficial owners, among other matters. AUSTRAC names the deed and deeds of variation for verifying the trust's details, not individuals' identities. | Each role links to its deed page; your AML/CTF compliance officer signs off. | A trust register with a page link per field, and an exception list | Source, as at 5 May 2026 |
Last reviewed
General information, not legal advice.
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