CDD on an existing client who now wants a designated service

People search “existing client new designated service CDD” when a tax practice’s long-standing client now wants a service the program treats as designated. 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 pre-commencement cohort is on pre-commencement customers. Monitoring after onboarding is on ongoing customer due diligence for a small firm. The sector map is /tranche-2.

The relationship is old. The service is new.

Accountants meet this on a Tuesday: a client whose returns you have lodged for years asks you to set up a company, move a trust, or help with a transaction your program calls a designated service. The working-paper file shows you know their affairs. It does not show you completed initial customer due diligence for that service. Knowledge is not a record under the program.

Do not file them under “existing customer” unless they were already a customer for a designated service. The transitional rules AUSTRAC wrote for customers you had at commencement are a cohort with their own timing. A person who was only a tax client is not that cohort. This page does not apply those transitional dates to a new instruction.

• Name the new service. Write the instruction in the program’s words. “Helping a good client” is not a service line.
• Open an AML file. The tax file can sit beside it. It does not replace it.
• Check the entity they named. The individual you know may be asking for work for a company. That is KYB.
• Do it before the work. Initial CDD is not a follow-up after the company is registered.

Which history counts

Sort the client before you quote. The sort takes one minute and stops the firm giving a designated service on the strength of a Christmas card list.

Where the existing-client page stops

This page is a new designated service for a client you already know. It is not pre-commencement timing and it is not ongoing monitoring. Those are pre-commencement customers and ongoing customer due diligence for a small firm. FreeAML does not decide the service is designated and does not convert a tax file into CDD.

The firm suite is A$0. The check for the new service is client-pays.

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. The firm suite does not treat a tax history as a completed check, and the history is not included as KYC. Confirm the live amounts on FreeAML pricing. FreeAML does not treat a tax file as customer due diligence or classify the new service.

Frequently Asked Questions