Alternative ID for First Nations clients

People search “alternative ID First Nations AML” when a suburban firm has a First Nations client coming in tomorrow and the program says nothing about an alternative path. Checked against AUSTRAC's initial customer due diligence overview on 4 October 2026. This is general information, not legal advice. This page does not reproduce that guidance. The obligation staff are applying is customer due diligence requirements. How a checklist is framed is AUSTRAC's customer due diligence checklist. The sector map is /tranche-2.

Written before the appointment

Alternative ID for First Nations clients is a program problem, not a reception problem. If the only line in the program is passport or driver licence, a First Nations client who holds neither will hit a wall that the firm should have seen coming. The repair is to write a path, using AUSTRAC's guidance, before tomorrow's appointment. It is not to improvise in the interview.

The path is not a concession. The risk judgment is the same judgment you apply to any customer. You do not rate the file as low because you want the appointment to succeed, and you do not rate it as high because the documents are unfamiliar. This page does not name documents that path may use.

• Write it down first. A path that exists only in someone's memory is not a path.
• Keep the same risk test. Identity method and risk rating are different lines on the file.
• Do not make the client design it. Asking them to bring anything is not a procedure.
• If you are not ready, say so. Postponing the designated service is better than inventing a standard in the room.

The appointment, without a document list

Train the person who meets the client on what they may say. They may say the program has a set path. They may not negotiate a new one. They may not promise that any paper will do, and the table is about conduct, not about papers.

Where the First Nations page stops

This page says the path must exist in the program and must not be a lower standard. It is not a list of documents, and it is not legal advice on what AUSTRAC will accept. Read the guidance, then write the program.

The general shape of the obligation is customer due diligence requirements. This page does not restate those steps.

What the client pays

On FreeAML the firm suite is A$0. The firm emails the client a link. Verification is client-pays. On the public list a personal KYC check is A$20 and a company or trust KYB check is A$40. Use KYB when the customer is a company or a trust. A respectful path is not a discount, and it does not move a required check off the client and into the firm suite. Confirm the live amounts on FreeAML pricing. FreeAML does not set an alternative identification standard or decide that a client may proceed without one.

Frequently Asked Questions