Do not show the client your red flag list
Do not show the client your red-flag list, because that list is how staff decide what to escalate. Handing it over tells the client what the firm treats as sensitive.
Quick answer
You may tell a client that the program requires identification before a designated service. You do not walk them through which facts would cause a report, and you do not email the list, a summary of the list, or a cleaned-up version. What you must not say on a live suspicion is a different page. This one only keeps the list inside the firm.
People search βdo not show client the red flag listβ when a principal is asked to email the firm's internal red-flag list so a client can 'get the file right'. Checked against AUSTRAC's tipping-off page on 4 October 2026. This is general information, not legal advice. This page does not reproduce that guidance. What not to tell a client is tipping off: what not to tell the client. The sector map is /tranche-2.
The list is a control
Do not show client the red flag list is a rule of handling, not a slogan. The list tells staff which facts to escalate, and a client who reads it learns which facts to avoid mentioning. That is why it stays in the office. Editing a few lines, or turning it into a preparation guide, does not change what it is.
Ordinary program talk is still allowed. You can say identification is required before the service, and you can email the check link. You cannot explain which combination of facts would make you report. This page does not script that conversation, and it does not decide whether a suspicion exists.
- Keep the list with staff. People who apply the program can see it. The client cannot.
- Do not attach it to the link. The email that asks the client to complete a check carries the link, not your indicators.
- Refuse the shortened copy. A one-page version for the client's accountant is still the list. Do not send it.
- Separate ordinary words from suspicion. Saying the program needs identification is ordinary. Saying what would trigger a report is not. The tipping-off page carries that line.
Who may see which paper
A sorting aid for papers a client asks to see. This table does not reproduce AUSTRAC's tipping-off guidance.
| Paper | Who may see it | Why |
|---|---|---|
| Internal red-flag list | Staff who need it for the program | It is a control, not a handout |
| A shortened or 'friendly' copy | Still only those staff | Editing it does not make it a brochure |
| The fact that identification is required | The client | That is an ordinary program step |
| Whether you have formed a suspicion | Not the client | Telling them is the tipping-off problem |
Where the red-flag-list page stops
This page keeps the list internal. It is not a script for client conversations. How to talk about the obligation without tipping off sits on how to talk about AML with clients. This page does not publish indicators.
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 client-facing version of the red-flag list is not included in the firm suite. Confirm the live amounts on FreeAML pricing. FreeAML does not draft a client-safe version of your red-flag list, or decide whether you have formed a suspicion.
π Related Resources
Free KYC Check β
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Free AML Program β
Board-ready AML/CTF Program template. All 10 AUSTRAC sections included.
Risk Assessment Generator β
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Free AML Training β
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AUSTRAC Reporting Tools β
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Frequently Asked Questions
Keep the list on the staff side.
The firm suite is A$0. The client pays the check. The red-flag list is not a document you attach to that link.
Open the Tranche 2 guideQuestions: team@freeaml.com.au