Delayed initial CDD: when you may start before ID is finished

A search for “delayed cdd austrac” from a law practice is a timing question: may we open the file before the client has finished ID? Sometimes, on the conditions AUSTRAC publishes. Often, no. Checked against AUSTRAC’s delayed initial customer due diligence page on 2 October 2026 (page last updated 22 April 2026). This is general information, not legal advice. This page does not reproduce that guidance. The default, when delay does not apply, is customer due diligence requirements. The sector map is /tranche-2.

Delay is a permission, not the ordinary file

The ordinary rule is to finish initial customer due diligence before the designated service starts. Delay exists only in the circumstances the page lists, and only if the firm can show the preconditions. Inconvenience for you or the client is not one of them. AUSTRAC says that expressly.

• Essential, and low additional risk. Before you start, you need reasonable grounds that delaying is essential to avoid interrupting the ordinary course of business, and that the additional money-laundering risk of waiting is low. You must be able to show how you reached both.
• Policies first. The program has to say when delay is appropriate, that you will finish as soon as reasonably practicable and no later than the timeframe in the Rules, and how you will manage the risk of an unfinished check.
• As soon as reasonably practicable. The outer date is a backstop. It is not a reason to wait until the last day. What is reasonably practicable is an objective test on your facts.
• Not every service. A jewellery purchase and a casino cash-out are AUSTRAC’s examples of work where delay will not be appropriate, because you may never see the customer again. Do not borrow a property clock for a different designated service.

The conveyancing clock, and the 15-day form

Where you provide professional services related to a sale, purchase, or transfer of real estate, AUSTRAC says you can start helping a buyer or transferee before initial CDD is finished. The example on the page is a legal practitioner or conveyancer assisting a buyer of real estate. You must then complete initial CDD by the earlier of 28 days after the exchange of contracts, or 3 days before the initially agreed day for settlement. If settlement is agreed sooner than that 28-day limb, the 3-day limb is the earlier date. You do not have 28 days merely because the page mentions 28. Confirm the live paragraph. This page does not reproduce it.

That 28-day figure is the updated one. AUSTRAC’s conveyancer starter kit updates, release 1.1 dated 10 June 2026, record that the delayed CDD timeframe for conveyancing services provided to buyers changed from 15 days to 28 days after exchange of contracts, or 3 days before the initially agreed settlement date. The real estate starter kit updates record the same change for counterparties, from 15 days to 28 days. A form in the practice that still says 15 days is the older kit. Refresh it from the current library. Do not treat 15 days as the live outer date, and do not invent a third number between them.

Do not settle while the check is still open

The permission to start is not permission to settle, transfer, or treat identity as done. AUSTRAC’s separate Australian-establishment path says you complete initial CDD before you transfer money or property. The property clocks have their own outer dates. Either way, a file with ID still outstanding is an open file. The day-to-day legal workflow, once you know a check is required, is AML checks for lawyers. Assisting a transfer, for a conveyancer, is AML for conveyancers.

FreeAML does not decide that delay is allowed, and it does not count 28 days, 15 days, or 3 days. What the firm account shows is whether the check is finished. A request sits pending until the client opens it, in progress while it is open, and complete when it is done. A company check with beneficial owners still outstanding stays in progress, so it does not read as complete. That incomplete status is how the practice avoids settling blind: the matter list still shows the check as open. The invite is by email. The firm suite is A$0. 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. Confirm the live amounts on FreeAML pricing. The product does not replace austrac.gov.au, and it does not lodge anything with AUSTRAC.

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