AUSTRAC customer due diligence: initial versus ongoing

People search “austrac customer due diligence” and want one checklist. AUSTRAC publishes the duties in two places: the overview of initial customer due diligence and the overview of ongoing customer due diligence. Checked on 2 October 2026. This is general information, not legal advice. This page does not reproduce either overview. The sector map is /tranche-2.

Initial customer due diligence

Initial customer due diligence is the opening of the file. Before you provide the designated service, you establish on reasonable grounds who the customer is, and you verify enough information for the risk. The matters themselves, in plain English, are customer due diligence requirements. This page does not repeat that list.

• It sits on this matter. A long relationship is not an exemption. A new designated service is a new question.
• Delay is narrow. Permission to start before identification is finished is delayed initial CDD. It is not the default, and it is not this comparison.
• The client fills in the check. What they complete, and what they must not be asked to write, is what the client fills in on an AML form.

Ongoing customer due diligence

Ongoing customer due diligence starts once the service is underway. You monitor the customer for behaviour that does not fit what you know, and you review the risk and the KYC information when your program says to. For a small firm that is a trigger, a look, and a record. The shape of that record is ongoing customer due diligence for a small firm. It is not a bank alerts desk, and this page does not turn it into one.

This page is the split. It is not the other notes.

The order of jobs on a new matter is the customer due diligence checklist. That page is a sequence. This page is not the checklist. It is the timing: initial versus ongoing. Enhanced customer due diligence is a third label, used when standard checks cannot carry the risk. When that extra work starts is enhanced customer due diligence. Do not treat “enhanced” as a synonym for “ongoing”.

Both timings can use the same check. The firm still decides.

The FreeAML firm suite is A$0. The firm emails the client a link when the program says a check is due, at the start or on a later trigger. 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. Confirm the live amounts on FreeAML pricing. A company or a trust uses KYB. FreeAML does not decide that the service is in, and it does not sell a monitoring desk as ongoing customer due diligence.

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