Customer due diligence checklist for a new matter

People search “customer due diligence checklist” when a new matter has just opened and they want the sequence, not the statute. The requirement underneath the list is customer due diligence requirements. Checked against AUSTRAC’s initial CDD overview on 2 October 2026. This is general information, not legal advice. This page does not reproduce that overview. Whether the matter is in the regime at all is /tranche-2.

Open the matter before you collect a document

A checklist that starts with a passport collects the wrong thing on a file that is not a designated service. Run the service question first. The sorting aid is the designated services decision tree. If the matter is out, stop. Do not verify a client “just in case” to justify the software.

1. Confirm the engagement is a designated service, and write which one. If it is not, this list is the wrong tool.
2. Name the customer on this retainer. A company or trust is the customer, not only the person who emailed.
3. Note who the service is for, if that is someone other than the customer, and who is acting for them, with authority.
4. If the customer is not an individual, list the beneficial owners your program says you must identify. The test is what a beneficial owner is.
5. Record the nature and purpose of the work, so later monitoring has a baseline.
6. Rate the money-laundering risk on this file. Depth follows the rating. Enhanced steps, where they apply, are enhanced customer due diligence.
7. Send the verification the program requires. That is the identity or entity check. On FreeAML the client pays it.
8. Record the PEP and sanctions result for the people in scope, and the decision to start or not. Do not start if you cannot establish the matters.

Which step is the client-pays check

Steps 1 to 6 are the firm’s. The program, the officer, and the risk note do not have a check price. Step 7 is the verification. FreeAML emails the client a link. The client completes the identity or entity step and pays for that check. On the public list a personal KYC check is A$20 and a company or trust KYB check is A$40. A further person the program requires is a separate check, not a bundle inside the entity figure. Confirm the live amounts on FreeAML pricing. The difference between the two checks is KYB and KYC.

The path into that verification is /aml-check. How a professional firm runs the same step day to day is KYC verification for professional firms. What the check is meant to cover, beyond a photo, is what an AML check covers.

Do not tick the last box early

AUSTRAC’s overview says you establish the matters on reasonable grounds before the designated service starts, unless a delay rule actually applies. A collected form is not a verified matter. A company extract is not every beneficial owner. A clear screen is not enhanced customer due diligence where the risk is high. If you cannot get to reasonable grounds, you do not start. Some files may delay part of the check. That is a narrow path, written up as delayed initial CDD, not the default for a new matter.

After the first day, the file stays open in a different sense. Ongoing customer due diligence is the rest of the relationship, which is ongoing customer due diligence for a small firm. The checklist on day one does not retire that duty. FreeAML does not decide the service is designated, does not enrol the firm, and does not replace austrac.gov.au. The firm suite is A$0. The client pays the ID or KYB step when the program requires it.

Frequently Asked Questions