Law firms can now meet both AML and VOI obligations through a single platform. First AML’s Source solution integrates identity verification, client authorisation and AML onboarding into one workflow, reducing duplication, improving compliance and ensuring ARNECC and AML audit readiness. It supports clause 6.5.2(b) compliance, DVS checks and biometric VOI, with custom workflows based on matter type and risk level.
The rising pressure on legal compliance
With Tranche 2 of Australia’s anti-money laundering (AML) reforms on the horizon, legal firms are preparing to enter a new regulatory era. But while many firms are focused on AML readiness, there’s a parallel obligation that can’t be overlooked: verification of identity (VOI) under ARNECC’s model participation rules (MPR). For firms handling property, conveyancing or transactional matters, VOI is not new, but integrating it with AML requirements in a scalable, auditable way is an emerging challenge.
For large law firms already operating under pressure, managing both regimes can lead to inefficiencies, duplicated effort and compliance blind spots. Many are now asking: "What’s the best way for law firms to comply with both AML and VOI without adding complexity?"
The answer is Source. First AML’s integrated AML and VOI compliance solution for legal professionals offers a unified workflow that supports full regulatory coverage with no duplication, no gaps and no manual workarounds.
The regulatory landscape: AML meets VOI
Australian law firms are on the cusp of formal AML regulation, with final obligations set to be released in August 2025. These will likely include customer due diligence (CDD), sanctions and politically exposed person (PEP) checks, source of funds verification and ongoing monitoring.
At the same time, ARNECC’s MPR impose VOI obligations on practitioners conducting property and other registry-related transactions. Clause 6.5.2(b) of the MPR specifically requires practitioners to “take reasonable steps to verify the identity of a client” using prescribed or non-prescribed procedures depending on the context.
For those looking for how to meet Clause 6.5.2(b) verification requirements, Source provides a direct and defensible way to embed those steps into a compliant, firm-wide workflow.
Although VOI and AML share common elements such as identity verification and document collection, they are governed by separate frameworks. Traditionally, firms have handled them through different tools, teams and processes, creating unnecessary duplication and exposing the business to risk.
Common compliance challenges: duplication, disconnection and gaps
In practice, managing AML and VOI separately often leads to:
- Duplication of identity checks
Clients are asked to verify their identity multiple times; once for VOI and again for AML, damaging client experience and creating inefficiency - Siloed systems and workflows
VOI is often handled through document management systems while AML is managed in separate tools or even spreadsheets. This disconnect makes it harder to ensure a complete audit trail - Manual workarounds and inconsistency
Staff may have to improvise how and when VOI is triggered relative to AML steps. That leads to inconsistent application of ‘reasonable steps’ and increases the risk of non-compliance - Lack of visibility for risk and compliance teams
Without a unified view of the client and matter, oversight is reactive not proactive
These issues are magnified in large law firms with high matter volumes, multiple practice areas and distributed teams. A fragmented approach is no longer viable.
Introducing Source: one platform, full coverage
Source by First AML is a purpose-built compliance platform that enables law firms to manage both AML and VOI obligations through a single, secure, auditable workflow.
It combines automated client onboarding, digital identity verification, biometric facial matching, document collection, risk assessment and audit logging into a seamless process that integrates directly into the firm’s matter lifecycle.
Whether you’re managing VOI and AML compliance for property law matters, or handling high-risk commercial clients, Source gives your firm a structured, scalable and regulator-ready solution.
Use case
Conveyancing matter with VOI and AML requirements
A client instructs your firm to act in the purchase of a residential property. This triggers VOI requirements under ARNECC as well as AML obligations under Tranche 2. With Source, VOI is automatically initiated alongside AML onboarding. The client receives a single secure webform to complete both processes including the VOI client authorisation form. Documents are verified against the DVS, face match is confirmed, and all actions are logged under both the client profile and matter for full audit traceability.
How Source works: step-by-step integration
Here’s how Source simplifies VOI while delivering AML compliance in parallel:
1. Matter created, VOI triggered
When a matter is opened in the firm’s practice management system, Source automatically triggers the appropriate workflow based on criteria like practice area, transaction type or jurisdiction. If the matter involves property or financial transfers, VOI is triggered alongside AML CDD.
2. VOI requirements selected
The compliance team selects the relevant VOI requirements directly within Source, including digital client authorisation forms. Options are customisable depending on what constitutes ‘reasonable steps’ for the matter - whether prescribed procedures, Document Verification Service (DVS) checks or biometric verification.
3. Secure VOI link sent to client
Clients receive a secure branded webform with clear instructions and an upload interface. The form supports digital signing, document uploads and photo capture. VOI and AML documents can be submitted in a single session, reducing friction and improving completion rates.
4. Client completes VOI
The client completes the VOI process using their smartphone or computer. Source supports both prescribed methods and custom firm policies and ensures consistency regardless of who is managing the matter.
5. Receipt, verification and audit logging
Documents are automatically verified against the DVS. AI-powered biometric tools confirm liveness and face match. Every action is timestamped, logged and linked to both the individual and the matter, creating a digital verification workflow with DVS and biometrics, thereby supporting ARNECC and AML audit requirements.
6. Documents stored and associated
All VOI and AML materials are automatically associated with:
- The individual’s profile so documents can be reused for future matters
- The specific matter ensuring end-to-end traceability and eliminating the need to hunt across systems during an audit
Use case
High-risk client flagged as a foreign PEP requiring enhanced due diligence with biometric VOI
A corporate client is flagged during onboarding as having a beneficial owner who is a foreign politically exposed person (PEP). The compliance team configures the Source workflow to trigger a biometric verification to support VOI and further enhanced due diligence checks. Source of funds/wealth documentation is securely collected, identity is verified via DVS and face matching. All actions are logged under both the full client profile and matter for full audit traceability.
Key benefits for large law firms
Source isn’t just a tool. It’s an operational model for modern compliance. Here’s how it delivers real value:
True compliance with clause 6.5.2(b)
Source operationalises ‘reasonable steps’ under ARNECC by giving firms flexible auditable workflows aligned to risk level, matter type and client location. No more vague policies or inconsistent practices, just defensible evidence-backed VOI.
One platform with no duplication
By integrating VOI into the same platform used for AML onboarding, Source eliminates the need for separate tools, logins or document storage. Your client verifies their identity once. Your team sees it once. Everyone’s time is respected.
Biometric verification built in
Advanced facial recognition and liveness detection tools provide high-assurance VOI even when working remotely. This meets ARNECC’s intent for robust technology-enabled verification.
Use case
Remote client onboarding for interstate litigation
Your Sydney-based firm takes on a client in Perth involved in a commercial dispute. The litigation matter doesn’t trigger VOI under ARNECC, but AML CDD is still required. Source adapts the workflow accordingly. The client uploads identification remotely and biometric liveness detection ensures the individual is who they claim to be. No in-person meetings or wet signatures are required.
Secure digital client experience
Clients receive a polished mobile-optimised experience that blends VOI and AML requests into one task, reducing drop-off rates and ensuring faster matter progress.
Customisable by risk, area and scenario
Not all matters are equal. Source allows you to tailor workflows based on what the law requires and what your firm needs. Whether it’s a low-risk family matter or a cross-border property transaction, the workflow adapts automatically.
Firm-wide consistency and oversight
Source standardises how VOI and AML are handled across offices, teams and individuals. Risk teams get visibility across all clients and matters and every action is logged for future auditing.
Use case
Reuse of VOI and AML data for repeat clients
A client who recently completed AML and VOI for a conveyancing matter now engages the firm for a family law matter. Since Source links identity documents and verification data to the individual, the team can use the pre-verified information where applicable to increase efficiency and reduce friction.
Move faster, stay compliant, do less
The age of siloed compliance systems is over. With regulation intensifying and client expectations rising, law firms can’t afford duplication, gaps or compliance uncertainty.
Source empowers large law firms to meet both VOI and AML obligations through a single streamlined process that is fully auditable, customisable and scalable across your practice. No more toggling between tools. No more repeated client requests. Just complete compliance from one platform.
Next steps
Book a personalised demo of Source and see how your firm can simplify AML and VOI without sacrificing control or coverage.
About First AML
First AML comes from the perspective of both a technology provider, but also as compliance professionals. Prior to releasing, First AML’s all-in-one AML workflow platform, we processed over 2,000,000 AML cases ourselves. Understanding the acute problem that faces firms these days as they try to scale their own AML, is in our DNA.
That's why First AML now powers thousands of compliance experts around the globe to reduce the time and cost burden of complex and international entity KYC. Source stands out as a leading solution for organisations with complex or international onboarding needs. It provides streamlined collaboration and ensures uniformity in all AML practices.
Keen to find out more? Book a demo today!