Guarantor on a related deal: customer or not

People search “guarantor AML CDD” when a guarantor appears on a related finance deal and the firm is about to open a second customer file without asking who receives the service. Checked against AUSTRAC’s overview of initial customer due diligence on 4 October 2026. This is general information, not legal advice. This page does not reproduce that guidance. Who you may start work for before checks finish is pre-commencement customers. The reporting-entity test is what a reporting entity is. The sector map is /tranche-2.

The guarantee is not the retainer

Guarantor AML CDD gets searched when a loan sits beside a conveyance or a business purchase. The bank’s form has a guarantor. The firm’s engagement has a client. Those names can differ; customer due diligence follows the person who receives the designated service, which your program defines; A signature on a guarantee, by itself, is not that definition.

A two-partner firm should write one sentence on the file: who receives the service we are providing. If the answer is the borrower, the guarantor is not the customer of that service merely because the bank asked for comfort. If the firm is separately engaged to advise the guarantor, that is a new question, and it is still the program’s question. This page does not answer it.

• Start with the service. Name the designated service on this matter. The customer is tied to that service, not to every name on the bank’s PDF.
• Do not clone the borrower file. A guarantor is a different person. Cloning the file pretends you already decided they are a customer.
• A related loan is context. It can change risk. It does not, by itself, add a customer.
• A separate retainer is a new file. If you advise the guarantor, open that question in the program. Do not hide it inside the borrower’s matter.

Sorting a related deal

Where this page stops

This page is the guarantor distinction. It is not the full customer due diligence procedure. That procedure is customer due diligence requirements.

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. Opening a customer file on a guarantor is not included, and neither is a check the program did not require. Confirm the live amounts on FreeAML pricing. FreeAML does not decide that a guarantor is the customer.

Frequently Asked Questions