Elderly clients and AML: what reasonable steps look like

People search “AML clients without smartphone” when a conveyancer on settlement has an older client who cannot finish the usual on-screen check without someone beside them. Checked against AUSTRAC’s overview of initial customer due diligence on 4 October 2026. This is general information, not legal advice. This page does not reproduce that guidance. A delay the program allows is delayed initial customer due diligence. How a visual check differs from CDD is VOI versus CDD. The sector map is /tranche-2.

Help is not a substitute client

An older client on a conveyance often wants a family member to deal with the paperwork, and customer due diligence does not move to that relative. The person being identified is the customer the program names, usually the buyer or seller on the contract. Reasonable steps are the ones the program already wrote for a client who cannot finish the usual collection alone, and sitting in your office while they complete their own check is help. Sending the link to someone else to complete in their place is a different person.

This page does not list stand-in documents, and AUSTRAC’s initial due diligence overview is the shape of the obligation, and your program is the procedure. A blog that invents an alternative identity pack is doing the program’s job badly. If the check cannot be completed, the program says whether the designated service waits. Patience is not a waiver.

• The client does the check. A child, a neighbour, or the conveyancer’s clerk can sit beside them. They do not become the customer on the result.
• Use the program’s fallback. If the program names another path when the usual collection fails, follow that path. Do not draft a new one on the file.
• Pause where the program pauses. Settlement convenience is not a reason to provide the designated service before the step the program requires.
• Write what you did. Who was in the room, that the client completed their own check, and what remained outstanding. A memory of being helpful is not a file note.

Help, delay, and a different person

The checklist shape of ordinary CDD, which this page does not rewrite, is the AUSTRAC customer due diligence checklist. Keep the elderly-client question here.

Where the reasonable-steps page stops

This page is how a conveyancer helps an older client without replacing them. It is not an alternative-identity catalogue and it is not the delay rule. FreeAML does not complete the check for the client.

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. Help in the office is not a different price, and a relative does not become the paying customer by holding the link. Confirm the live amounts on FreeAML pricing. FreeAML does not invent an alternative identity pack or let someone else complete the client’s check.

Frequently Asked Questions