Enhanced CDD requirements: PEP, sanctions, high risk

People search “enhanced customer due diligence requirements” when a conveyancer on a Friday settlement is told the buyer may be a foreign politically exposed person. Checked against AUSTRAC's enhanced customer due diligence guidance on 4 October 2026. This is general information, not legal advice. This page does not reproduce that guidance. The longer walk-through is enhanced customer due diligence in Australia. Name screening as its own topic is sanctions screening. The sector map is /tranche-2.

Three triggers, not one button

Enhanced customer due diligence requirements are not a premium package you buy for every file. They are the measures your program turns on when a defined trigger is present. On a conveyancing settlement the trigger is often a person who may be politically exposed, a name that needs a sanctions look, or a file the program already rates high.

Those three are not interchangeable. You can have a PEP who is not a sanctions target. You can have a high-risk structure with no PEP in it. You can have a sanctions question that stops the file before any enhanced pack would have helped.

• A PEP is a status. The program says how you identify one and what extra measures follow. The title on a business card is not the test.
• Sanctions are a hard gate. A possible match is not a PEP form with more boxes. The program says who reviews it and when the service stops.
• High risk is your rating. It comes from the program's factors, not from a hunch on settlement day.
• Standard files stay standard. Enhanced measures on every conveyance hide the files that actually need them.

What extra usually means

The extra steps are whatever the program wrote down: more information about source of funds, a senior person to approve, or a further check on a related individual. This page does not add a step AUSTRAC did not put in your program. A conveyancer records which trigger fired, which measure followed, and who approved.

Where the trigger page stops

This page sorts PEP, sanctions, and high risk. It is not the full enhanced-due-diligence procedure. That procedure is enhanced customer due diligence in Australia.

It does not list sanction regimes or penalty amounts. The screening page is the place for how a name check fits the program.

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. Enhanced measures can mean more than one check, and each check stays client-pays rather than moving into the firm suite. Confirm the live amounts on FreeAML pricing. FreeAML does not rate a customer high risk or decide that a sanctions match may proceed.

Frequently Asked Questions