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Compliance
October 4, 20269 min read

Biometric liveness: what the client sees during the check

Biometric liveness, for the client, is the face-match step on the screen in front of them. They see a prompt, then a result, and they do not see your program.

Quick answer

On a real estate file the client opens the link and completes the face-match step on the screen, and a pass is a result you keep. A fail is a reason to stop and follow the program, not a cue to coach a second pose. The firm suite is A$0 and the client pays the check. The screen step is not the agency's whole CDD.

People search “biometric face match AML client” when an agency wants to know what the client actually sees during the face-match step, before anyone calls it customer due diligence. Checked against AUSTRAC's glossary entry for KYC information on 4 October 2026. This is general information, not legal advice. This page does not reproduce that guidance. How a live check differs from a certificate sighting is VOI versus CDD. The sector map is /tranche-2.

The prompt, then a result

The client does not see your risk assessment. They see the screen the check uses for the face-match step: a prompt, a chance to match the face to the document, and a pass or a fail. Staff in the agency see the result that comes back. They do not watch the step in place of the check.

A pass means that step returned a pass. It does not mean the company buyer is identified, and it does not mean the program's other questions are done. A fail means you stop. You do not tell the client how to adjust until the result flips.

  • Say what the screen is for. It is the face-match step in this check. It is not a staff member judging a face across a desk.
  • Keep the result. Store the pass or the fail on the file. A verbal 'they looked right' is not the result.
  • Do not coach a fail. Telling the client which angle will pass is not customer due diligence. Follow the program.
  • Leave the rest of CDD in the program. Source of funds, the customer, and a company or trust are not settled by a face on a screen.

What the agency stores

What the client sees, and what the agency is allowed to treat it as. This table does not reproduce AUSTRAC's KYC glossary.

On the screenWhat it isWhat it is not
A prompt to match a face to the documentThe face-match stepThe agency deciding the face in the office
A passA result to storePermission to skip the rest of CDD
A failA reason to stop and follow the programA cue to coach another try
The stored resultEvidence the step ranThe firm's AML/CTF program

Where the face-match page stops

This page is what the client sees on the screen during the face-match step. It is not the professional-firm walk-through of KYC. That sits on KYC verification for professional firms. A company or trust still needs KYB at A$40, paid by 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. The face-match step is part of the client-pays check, and coaching the client through a failed result is not included in the firm suite. Confirm the live amounts on FreeAML pricing. FreeAML does not decide that a face-match pass is your whole customer due diligence.

Frequently Asked Questions

Send the link. The client uses the screen.

The firm suite is A$0. The client pays. A personal KYC check is A$20. The face-match step is part of that check, not a separate firm fee.

Start a KYC check

Questions: team@freeaml.com.au