The trigger is a designated service, not a nervous client

“What triggers an AML check?” is usually a fear that every new file now starts with a passport. Checked against AUSTRAC's overview of initial customer due diligence on 5 October 2026. This is general information, not legal advice. This page does not reproduce that guidance. The before-and-after rule is customer due diligence before the designated service. The list of services is designated services. Accountants in particular should read designated services for accountants. The sector map is /tranche-2.

The trigger is the service

AUSTRAC says you complete initial customer due diligence before you start providing a customer with a designated service. The trigger is not the client's nationality, not a dollar amount someone mentioned in a forum, and not the fact that a bank also asked questions. It is your service. For a seller's agent, AUSTRAC says the designated service to the seller starts when the agency agreement is signed. For a conveyancer, a transaction can exist, and the service can start, when buyer and seller agree a price. For a professional taking a company-secretary role for a nominator, preparatory steps can already be the service. Read the guidance for the service you sell. Do not use one sector's start-line for another sector's file.

The reverse matters as much. Work that is not a designated service does not trigger the check. AUSTRAC's real estate page says private sales of residential property are not captured under those designated services. A business selling its own premises, where it is not in the business of selling real estate, is the example AUSTRAC gives of an incidental sale that is out. An accountant's ordinary compliance work is out unless the particular engagement is on the professional services list. Running a check “to be safe” on those files costs the client money and collects personal information you may not have an AML reason to hold.

A short test before you email a link

• Which item is this? If you cannot point at the designated service, stop.
• Has it started? Use AUSTRAC's start-line for that item, not the day you feel busy.
• Who is the customer? An agent brokering a sale has both parties. A professional under table 6 often has the person who instructed them.
• Person or entity? KYC for a person. KYB for a company or trust, then the people the program names.
• Is a delay rule real here? The 20-business-day discussion in AUSTRAC's delayed CDD guidance is not a general grace period. Do not start the service and promise the link later unless that guidance actually covers you.

Write the triggers you actually have into the program as a short list the receptionist can use. “Engagement includes a designated service: send the link before we start. Engagement does not: do not ask for identity documents.” That list will be wrong if it is copied from another firm. It will also be wrong if it says “all new matters” in order to avoid thinking. The cost of a needless check is the client's money and a personal-information holding you did not need. The cost of a missed trigger is providing the service without customer due diligence. The list is how you avoid both.

Where this page stops

This page is the trigger. The timing once you have decided is how long an AML or KYC check takes.

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. There is no subscription. Confirm the live amounts on FreeAML pricing. No designated service, no FreeAML charge. When you do send a link, the client pays. The firm does not keep a subscription warm for files that never trigger.

Frequently Asked Questions