Personnel due diligence for the person who runs CDD

People search “personnel due diligence AML” when a firm runs every check through one clerk and has personnel due diligence written only against the compliance officer. Checked against AUSTRAC's page on which personnel roles need due diligence on 4 October 2026. This is general information, not legal advice. This page does not reproduce that guidance. Training for people who are not specialists is AML training for non-specialist staff. The officer role is the AUSTRAC compliance officer. The sector map is /tranche-2.

The clerk with the link is the point

Personnel due diligence exists because some roles can help a customer through, or can look the other way. In a small firm the person who actually runs customer due diligence is often not the partner named as compliance officer. It is the clerk who emails the link, reads the result, and tells the partner the file is clear. That clerk can let a bad result sit, and the role is in.

Do not swing the other way and screen the entire office because AML has started. The test is the role, written in the program: access to the checks, and authority, formal or practical, to move the file on. Someone who books a room and never sees a result is not that role just because they sit near it. Training for non-specialists is the neighbouring page, and this page is who you do due diligence on.

• Follow the link. Who is allowed to email it, and who is allowed to accept the result. Those names are the start of the list.
• Include practical authority. If the office will not proceed until that clerk says yes, the clerk has the role, whatever the chart says.
• Do not stop at the officer. The officer oversees. The person who runs the checks can be someone else, and both can be in scope.
• Leave out roles with no path through. No access and no say over the customer is a different staff member. Write the difference down.

Who is in the role, in a small office

Where the personnel page stops

This page is personnel due diligence for the person who runs the checks. It is not the training course for everyone else, and it is not the officer's job description. Those are AML training for non-specialist staff and the AUSTRAC compliance officer.

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. Personnel due diligence on your own clerk is not a client-pays KYC check, and the client's verification stays a separate client-pays check. Confirm the live amounts on FreeAML pricing. FreeAML does not screen your staff or decide which roles need personnel due diligence.

Frequently Asked Questions