Ongoing CDD when you only see the client once

People search “one off matter ongoing CDD” when a conveyancer finishes settlement and wonders whether the file now needs a review every twelve months. Checked against AUSTRAC's ongoing customer due diligence overview on 4 October 2026. This is general information, not legal advice. This page does not reproduce that guidance. How a small firm sets ongoing due diligence generally is ongoing customer due diligence for a small firm. What to watch on the transaction is the transaction monitoring guide. The sector map is /tranche-2.

The matter is the monitoring window

Ongoing due diligence sounds like a bank's yearly refresh. A conveyancer who acts on one transfer does not have that relationship. You do have a file that can change between instruction and settlement, and that interval is the window. A third party appears as the source of funds, a nominee is named, or the price moves with no reason the file explains, and noticing that is the ongoing work.

After settlement, read your program. If the relationship ended with the matter, a review next March is a diary entry you invented. If you keep acting, or the client is back for the next purchase, the program's ordinary settings apply to that next matter. Do not leave the current file unwatched just because you know there will be no anniversary letter.

• Define the window. From instruction to the end of the matter. Not from settlement to a date next year.
• Watch for a new party. A payer or a buyer who was not there at the start is a customer question, not a footnote.
• Watch for a story that breaks. Funds, price, or purpose that no longer match what you recorded.
• Close it when the program says it is over. Ending the relationship is a decision you record. It is not an excuse for silence during the matter.

During the matter, and after it

Where the one-off ongoing page stops

This page is ongoing due diligence for a client you see once. It is not the small-firm ongoing program, and it is not a monitoring manual. Those are ongoing customer due diligence for a small firm and the transaction monitoring guide.

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. A future review you do not need is not a check, and a new party who appears before settlement is a new client-pays check. Confirm the live amounts on FreeAML pricing. FreeAML does not set a review date after a one-off matter has ended or decide the file needs no watching at all.

Frequently Asked Questions