Australia’s anti-money laundering and counter-terrorism financing (AML/CTF) laws require members offering designated services to complete specific checks:

• before onboarding a new client, and
• for existing clients at 1 July 2026, if their circumstances change significantly.

These checks, customer due diligence (CDD), are designed to protect you, your business and the wider community from financial crime.

We have provided a PDF document you can customise for your practice and provide to potential and existing clients to help them understand how AML/CTF checks impact their relationship with you and your practice.

What you need to ask for

• Identity: You will need to sight, and record, documents that prove and verify a person is who they claim to be
• Business details: You will need to understand, and record, a client’s business structure, details of the directors including their director identification numbers (DINs) and verify the identity of any beneficial owners
• Purpose: You will need to assess that the service being sought makes sense for what you know about the client
• Source of funds: You may need to ask further questions to verify a client’s source of funds or how their wealth has accumulated.

Combined, this information allows you to apply a risk rating to your client and determine the level of ongoing monitoring required.

If checks cannot be completed

If a potential client is hesitant to provide the necessary identification documents or answer questions about their business, you may choose to decline offering them your services. 

If a client’s actions make you suspicious that their source of funds or wealth, or the service they are seeking, may be related to a financial crime, also submit what you know about the client and their activities to AUSTRAC in a suspicious matter report. 

Ongoing monitoring

Once onboarded, you must keep client information up to date and monitor that they use the services in the engagement letter as intended. How often will depend on the risk rating you applied to the client.

If an existing client is hesitant to answer questions as part of your CDD update when their circumstances change or when they seek a new service, you may want to consider increasing monitoring or even offboarding the client.

This ongoing process helps you:

• understand your client and their business, and
• assess, review and update your risk assessment of the client against known and emerging money laundering and terrorism financing risks.

If ongoing monitoring raises concerns about a client’s actions, their source of funds or wealth or the service they are seeking you may need to ask more questions. Seek information to confirm details, understand what triggered changes in your client’s circumstances or why a new service is being sought.

If you still have concerns that a client’s activities may be related to a financial crime, also submit what you know about the client and their activities to AUSTRAC in a suspicious matter report.