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Compliance
October 4, 20269 min read

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.

MomentCDD finished?Why firms miss it
First enquiryNot required yet, unless you are already providing the serviceA full pack for a person who never instructs
Engagement for a designated serviceBefore the service is providedThe letter goes out and the link goes out the week after
A delay the rules allowOnly on the conditions the program statesEvery file is marked delayed by habit
After the serviceToo late for initial CDDA 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.

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 check

Questions: team@freeaml.com.au