High-risk country clients: what enhanced CDD adds

People search “high risk country AML Australia” when a two-partner firm hears a client is connected to a higher-risk country and reaches for a new form instead of the program. Checked against AUSTRAC’s enhanced customer due diligence reform note on 4 October 2026. This is general information, not legal advice. This page does not reproduce that guidance. The measures in more detail are enhanced customer due diligence in Australia. A sanctions screen is sanctions screening in Australia. The sector map is /tranche-2.

Extra measures, not a second identity product

A country link is one reason a program moves a client from standard measures to enhanced ones, and the country is whichever your program treats as higher risk, read against the sources AUSTRAC tells firms to use. A blog that names countries will be stale and will be wrong at the edges. High risk country AML Australia, on this page, is what you add once the program has already made that call. You do not add a private list because a matter feels foreign.

Enhanced CDD sits on top of initial customer due diligence, and you still know who the customer is. You then do the extra things the program specifies. In practice those extras are more information, including where funds and wealth come from when the program asks, a decision by someone senior enough to accept the matter, and monitoring that is closer than the low-risk file. This page does not reproduce the reform note and does not issue a document checklist.

• Use the program’s countries. If the program does not treat the country as higher risk, a hunch is not a new rating. Update the program if the hunch should have been a rule.
• Keep sanctions separate. A country factor is not a designated-person match. Run the screen the program requires, and do not merge the two results into one word.
• Senior approval is a person. Name who can accept the matter. In a two-partner firm that may be one of the partners, and the file should say which.
• The check is still the check. KYC for a person and KYB for a company or trust. Enhanced measures do not swap the price or cancel the link.

What actually changes on the file

The baseline, before any country factor, is customer due diligence requirements. Do not rebuild that page here.

Where the country-risk page stops

This page is what enhanced CDD adds after a country call. It is not a country list and it is not the sanctions procedure. FreeAML does not rate countries or approve the matter.

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 are not a surcharge on the list price, and the underlying check is still client-pays KYC or KYB. Confirm the live amounts on FreeAML pricing. FreeAML does not name high-risk countries or decide that enhanced measures are satisfied.

Frequently Asked Questions