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Compliance
October 4, 20269 min read

Low medium high customer risk examples for accountants

Low, medium, and high customer risk examples help an accounting practice see the difference. They are illustrations for a suburban tax firm, not ratings AUSTRAC has assigned to your clients.

Quick answer

A long-standing local individual on an ordinary return, with no client money, is the shape of a lower-risk file. A new company on routine compliance sits in the middle until you know it. A new client who wants funds paid in and paid away, or an overseas owner you cannot explain, is the shape of a higher-risk file. Your program assigns the rating, and these examples do not.

People search “customer risk rating examples accountants” when a tax practice wants to mark every client low because the work is 'just tax returns'. Checked against AUSTRAC's customer risk ratings reform page on 4 October 2026. This is general information, not legal advice. This page does not reproduce that guidance. The questions you ask the business, rather than a single client, are on the ML/TF risk assessment for Tranche 2. What follows a higher rating is enhanced customer due diligence. The sector map is /tranche-2.

Illustrations, not a score AUSTRAC issued

Customer risk ratings belong in the firm's program. A blog can show the kind of file that usually pulls a rating up or down. It cannot rate a client's trust or the new cafe company, because it does not know them. Use the pictures to train the office, and then apply your own factors.

The mistake in a tax practice is treating 'compliance work' as a low rating. The service type is one factor. The client, the structure, the countries, and whether you will touch their money are others. A simple return for a person you have known for years is not the same file as a new group that wants you to receive settlement funds.

  • Lower risk looks familiar. A local individual, ordinary tax work, no client money, and a purpose you can state in a sentence.
  • Middle risk is unfinished knowledge. A new Australian company on routine accounts, with a clear owner, until the file is no longer new.
  • Higher risk is the odd request. Funds in and out, urgency before you know the parties, or an overseas owner the register does not explain.
  • The firm writes the rating. These bands are examples. They are not a matrix you can paste into the program and call adopted.

Four files on a tax-practice desk

Illustrative files for an accounting practice. This table does not reproduce AUSTRAC's risk-rating guidance, and it does not rate your clients.

File on the deskThe shapeWhat people skip
Ten-year individual, salary return, no client moneyLowerRe-rating them high because AML feels new
New local company, clear director, annual accounts onlyMiddle, until you know themCalling them low on day one because the job is 'just accounts'
New client, please receive the sale proceeds and pay the suppliers this weekHigherTreating the trust account as a favour outside the rating
Company owned offshore, purpose of the engagement still vagueHigher until the story is clearStopping at the Australian shelf company

Where the example ratings stop

This page is example shapes for an accountant's customer ratings. It is not your business-wide risk assessment, and it is not the enhanced due diligence steps. Those are the ML/TF risk assessment for Tranche 2 and enhanced customer due diligence.

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. A risk rating is not a check, and the verification your program requires for that rated customer is a separate client-pays check. Confirm the live amounts on FreeAML pricing. FreeAML does not assign your customer risk ratings or adopt these examples as your matrix.

Frequently Asked Questions

The rating is yours. The check is the client's.

The firm suite is A$0. The firm emails the client a link. The client pays. KYC is A$20 for a person. KYB is A$40 for a company or trust.

Start a KYC check

Questions: team@freeaml.com.au