Alternative ID for clients without a standard passport or licence

People search “identifying individuals without standard ID AML” when a client of a two-partner firm has neither a passport nor a driver licence and the file is otherwise ready. Checked against AUSTRAC's glossary entry for KYC information on 4 October 2026. This is general information, not legal advice. This page does not reproduce that guidance. Verification of identity is a different job from customer due diligence, on VOI versus CDD. The ordinary check is the KYC check guide. The sector map is /tranche-2.

The program has the path, or the service waits

Identifying individuals without standard ID AML is not a scavenger hunt. The client does not have a passport or a licence. The question is whether the program already describes what else, if anything, can complete initial customer due diligence for that person. If it does, staff follow that writing, and if it does not, the designated service waits.

This page will not name substitute documents. A blog list would be an invented standard, and staff would treat it as permission. AUSTRAC's guidance and your program are the only sources for that path. A verbal assurance from the client is not a path.

• Look at the program first. The alternative is either written there or it is not available today.
• Do not build a bundle at reception. Documents chosen on the spot are not the program.
• Do not lower the risk to make the file fit. Missing documents are not a reason to rate the customer as easier.
• Record the refusal. If you do not proceed, the file should say the program had no path, not that the client was difficult.

Decisions, not a document menu

Sort the file by decision. The table deliberately has no document names. Adding a column of acceptable papers would be the list this page refuses to write.

Where the no-passport page stops

This page is the gap where standard photo ID is missing. It is not a document menu, and it is not VOI for a land dealing. VOI compared with CDD is VOI versus CDD.

A First Nations client's path is a separate program question. Do not use this page as a shorter test for any group of clients.

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. An unfamiliar set of documents does not move the check into the firm suite or cancel it. Confirm the live amounts on FreeAML pricing. FreeAML does not invent an alternative document list or decide that this client may proceed without the program's path.

Frequently Asked Questions