What an AML check covers for an Australian firm

Search “aml check” and the first rows are often acute myeloid leukaemia. This page is the other AML: anti-money laundering for Australian firms after 1 July 2026. It is general information, not legal advice. The official list of what you must establish is AUSTRAC’s initial customer due diligence overview.

Four things the check is actually for

Firms ask for “an AML check” when they mean the evidence pack. AUSTRAC does not sell a single product by that name. The work splits into four jobs. Miss one and the file is still open.

Identity is the first row, not the whole check. A verification-of-identity pack can support “who is this person?”. It does not name the beneficial owners of a company, and it does not record a sanctions result or a risk rating. Sanctions screening sits next to the PEP question. AUSTRAC’s page on persons designated for targeted financial sanctions is the official note. A match is a stop-and-decide event for the firm, not a green tick.

What this page is not

• Not a medical AML search. Blood tests, leukaemia staging, and hospital “AML panels” are a different acronym.
• Not a replacement for how to run a free AML check. That page is the workflow and the zero-seat offer. This page is the scope: what the check has to cover.
• Not the VOI-versus-CDD argument. That split is is AML just VOI?. Read it when a conveyancer says the identity certificate is finished and the AML file is not.
• Not a reason to collect a passport from every email address in the inbox. The duty sits on a designated service. Map the matter on /tranche-2 first.

A short file that a reviewer can follow

1. Name the designated service and the customer. If you cannot name the service, you are not ready to run the check.
2. Establish identity for the customer, and for anyone acting for them.
3. If the customer is a company, trust, or other entity, name the beneficial owners and check the people your program says must be identified.
4. Record the PEP and sanctions result for the people in scope. Do not bury a match inside a PDF nobody opens.
5. Write the risk rating and whether the service may start. If a matter is still open, do not start.

Higher-risk matters can also need source of funds or source of wealth. That is enhanced customer due diligence, described on AUSTRAC’s enhanced CDD page. It is extra depth, not a fifth product you buy instead of the four rows above.

Where FreeAML fits

The firm suite is A$0. When your program says the matter needs an AML check, FreeAML emails the customer a link and verification is client-pays. Current amounts are on FreeAML pricing. The firm’s cash cost for that check is A$0 when the customer pays. The product collects the evidence. It does not decide that the service is designated, that the risk is acceptable, or that you may start work.

Frequently Asked Questions