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 screen | What it is | What it is not |
|---|---|---|
| A prompt to match a face to the document | The face-match step | The agency deciding the face in the office |
| A pass | A result to store | Permission to skip the rest of CDD |
| A fail | A reason to stop and follow the program | A cue to coach another try |
| The stored result | Evidence the step ran | The 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.
📚 Related Resources
Real Estate AML Toolkit →
Complete compliance toolkit for property agents.
Real Estate AML Guide →
Everything agents need to know about Tranche 2.
Free KYC Check →
Verify customer identity in 60 seconds. Government ID + AML screening.
Free AML Program →
Board-ready AML/CTF Program template. All 10 AUSTRAC sections included.
Risk Assessment Generator →
AI-powered ML/TF risk assessment. 20-page compliant report in 5 minutes.
Free AML Training →
Online courses for staff. CPD-certified certificates included.
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 checkQuestions: team@freeaml.com.au