Refusing a customer you cannot identify

People search “refuse customer AML Australia” when a suburban agency has an unconditional deadline and a buyer whose identity still does not match the file. 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. A permitted delay is a different rule, on delayed initial customer due diligence. What you must not reveal is what not to tell a client. The sector map is /tranche-2.

No identity, no designated service

Initial customer due diligence is how you come to know the customer before the designated service, unless a delay your program actually allows applies. If the information does not come, or it does not match the person, the agency does not invent a way through. AUSTRAC’s overview is the frame. This page does not reproduce it.

Refusal here means you do not provide the service. It does not mean a speech about money laundering. The client can be told that identification is incomplete, so the service cannot proceed. Anything about a suspicion belongs on the tipping-off page, not in a counter speech.

• Try the check the program names. Email the link. Record the date. A refusal without that attempt is a different failure.
• Do not exchange to save the weekend. An unconditional deadline is a commercial fact. It is not permission to skip identification.
• Say the service cannot proceed. Give the reason as incomplete identification. Do not add why you are worried.
• Write the stop. Who decided, on which file, and that the designated service did not go ahead. A verbal “we will not proceed” disappears.

Stop, delay, or continue

Three outcomes get argued at the desk. Only one of them is refusal. Name it so staff do not call a skip a delay.

Where the refusal page stops

This page is the stop when identification fails. It is not the delay rule and it is not the tipping-off rule. Those are delayed initial customer due diligence and what not to tell a client.

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. The decision to refuse a file is the firm’s, and that decision is not a product included in the firm suite. Confirm the live amounts on FreeAML pricing. FreeAML does not refuse the customer for you or tell you what to say to them.

Frequently Asked Questions