When in the client lifecycle CDD has to be finished
Initial customer due diligence is finished before you provide the designated service, unless the program uses a delay the rules allow. The first meeting is not the deadline; the service is.
Quick answer
Find the moment the designated service starts, then finish customer due diligence before that moment. A quote, a coffee, or last year’s tax return is earlier than the service. A delay is a narrow exception on its own page, not a habit. Pre-commencement customers are a different problem; the client pays the check; the firm emails the link in time for that moment, not after it.
People search “CDD before designated service” when a firm has opened a file, taken instructions, and is about to do the thing that is actually the designated service. 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. The exception is delayed initial customer due diligence. Clients who pre-date the regime are pre-commencement customers. The sector map is /tranche-2.
The service is the line, not the first hello
Lifecycle language makes firms check too early or too late. Too early means a full pack on a person who never becomes a customer of a designated service. Too late means the service has already been provided and the check is a record of a breach.
Map the service in the program first. For a conveyancer the line is the designated assistance with the transfer, not an early enquiry about a quote. For an accountant the line is the designated service, not the prior year’s return that pre-dated it.
- Name the service. If it is not designated, this timing rule is not the reason to run a check.
- Finish before you provide it. Identity, beneficial ownership, and the risk rating the program requires sit before that act.
- A delay is not the default. Use the delayed-CDD page only where the program and the rules allow it.
- Old clients are not this page. People who were clients before obligations started are the pre-commencement question.
Where the moment sits
Timing on a small-firm file. This table does not reproduce AUSTRAC’s initial CDD overview.
| Moment | CDD finished? | Why firms miss it |
|---|---|---|
| First enquiry | Not required yet, unless you are already providing the service | A full pack for a person who never instructs |
| Engagement for a designated service | Before the service is provided | The letter goes out and the link goes out the week after |
| A delay the rules allow | Only on the conditions the program states | Every file is marked delayed by habit |
| After the service | Too late for initial CDD | A check run so the folder looks complete |
Where the timing page stops
This page is the moment initial customer due diligence must be finished. It is not the delay exception, and it is not pre-commencement customers. Those are delayed initial customer due diligence and pre-commencement customers.
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. Timing advice is not included in the firm suite, and sending a link late does not move the legal moment. Confirm the live amounts on FreeAML pricing. FreeAML does not decide when your designated service starts, or approve a delay.
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Frequently Asked Questions
Send the link before the service, not after the apology.
The firm suite is A$0. The client pays. The firm emails a link. Personal KYC is A$20. Company or trust KYB is A$40.
Start a KYC checkQuestions: team@freeaml.com.au