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October 4, 20269 min read

When CDD is required before a designated service

Customer due diligence is required before you provide the designated service, unless your program allows a delay that the rules permit. Doing it after the service, because the file was busy, is late, and it is not a delay.

Quick answer

The default timing is before the designated service. A quote, an engagement letter, and settlement are different moments, and the program should say which moment counts as providing the service. A delay is a path the program wrote down in advance. It is not a decision made at the settlement desk, and the client pays the check whenever it is run.

People search “when is customer due diligence required” when a conveyancer wants to order the check after exchange because settlement is the date everyone remembers. Checked against AUSTRAC's delayed initial customer due diligence page on 4 October 2026. This is general information, not legal advice. This page does not reproduce that guidance. The delay path, where it exists, is delayed initial CDD. Work you do before the service starts is pre-commencement customer AML. The sector map is /tranche-2.

Before is the default

When is customer due diligence required is a timing question, and the default answer is before the designated service. A conveyancer who waits until after exchange because that is when the file feels real has chosen convenience. The program has to have allowed that moment. If it has not, the check is late.

Name the moment in ordinary language. For one firm it is accepting the instruction. For another it is lodging or exchanging. Write the moment in the program so staff do not renegotiate it on each file.

  • Default to before. The service should not be underway while identity is still an open question, unless a real delay path applies.
  • A delay is written in advance. It is a rule in the program for defined cases, not a favour on a Friday.
  • Busy is not a delay. Settlement pressure does not create an exception.
  • Record the moment. The file should show when the service started and when due diligence was done.

Three moments people mix up

Quote, start, and finish are different. Customer due diligence attaches to providing the designated service, not to the first email and not to the tax invoice. This page does not choose the moment for your service. It tells you to stop pretending every moment is the same.

Timing on a conveyancing file. This table does not reproduce AUSTRAC's delayed initial due diligence rules.

MomentWhat it usually isTiming mistake
First quoteA conversation, often before any serviceTreating a brochure as the designated service
Instruction acceptedOften the start, if the program says soWaiting because settlement is weeks away
A permitted delayA path the program already allowsInventing the path on this file
After the serviceLateRelabelling lateness as a delay

Where the timing page stops

This page is the default of before. It is not the catalogue of permitted delays. That catalogue is delayed initial CDD.

It does not decide whether your matter is a designated service. Scope is a different question from timing.

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. Running the check late does not move the fee into the firm suite, and running it early does not create a second charge. Confirm the live amounts on FreeAML pricing. FreeAML does not decide that your matter may use delayed customer due diligence or choose the moment the service starts.

Frequently Asked Questions

Send the link before the service, unless the program allows a delay.

The firm suite is A$0. The client pays. KYC for a person. KYB for a company or trust.

Start an AML check

Questions: team@freeaml.com.au