If a client left and returned after 1 July, does pre-commencement still apply?

People search “deregistered client AML CDD” when a tax practice sees a former client, whose company was deregistered, walk back in after 1 July and wants to rely on the old file. Checked against AUSTRAC’s page on transitioning existing customers on 4 October 2026. This is general information, not legal advice. This page does not reproduce that guidance. The continued-relationship timing is pre-commencement customers. A delay the program allows on a live matter is delayed initial customer due diligence. The sector map is /tranche-2.

A gap ends the old timing

Pre-commencement customers are the ones you already had when the obligations started, where the relationship continued. AUSTRAC’s transitioning guidance is about that group and the timetable for bringing their due diligence up to the new standard. This page does not reproduce it. A tax practice’s deregistered client AML CDD question is the opposite pattern: the company was deregistered, or the engagement letter ended, and months later someone wants the work again.

That return is a new customer for the new engagement, and initial customer due diligence applies at the time the program says it applies to a new matter. The old working papers can help you recognise the person. They are not a deferral, and they are not a completed check under the new program. If the relationship in fact never stopped, you are on the pre-commencement page instead, and you should say so honestly rather than use this one.

• Date the gap. When did the last engagement end, and when did the new one start. A gap across 1 July is the fact this page is about.
• Do not revive a deferral. Pre-commencement timing does not reattach because you still have the archive box.
• Run initial CDD on the new matter. The customer may be a new company with a familiar director. The company is still a new customer if that is who the engagement is with.
• Keep a continued client on the other page. If you never ceased to act, do not pretend there was a gap in order to choose a lighter story.

Left, stayed, or came back

Accountants as a sector, beyond this return-client point, are AML for accountants in Australia. This page stays with the broken relationship.

Where the returned-client page stops

This page is the client who left and came back. It is not the transition timetable for clients who stayed, and it is not a delay rule for a current matter. FreeAML does not decide that the old relationship continued.

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. An old file is not a paid check, and the new engagement’s verification is a fresh client-pays KYC or KYB check when the program requires it. Confirm the live amounts on FreeAML pricing. FreeAML does not decide that a returned client is still pre-commencement.

Frequently Asked Questions