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5 October 20268 min read

Your bank asks because it is already a reporting entity

Your bank asks customer due diligence questions because the bank is already a reporting entity. It has to know who you are and why you are using the account. A question from NAB, or from any other bank, is that obligation. It is not a finding that you have committed an offence.

Quick answer

Answer the bank about who you are and what the money is for, if you want them to keep providing the service. Do not read the form as a charge. Do not ask them whether they have reported you.

The search is usually “why is NAB asking me customer due diligence questions”, and the useful answer is not special to one brand. 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. What the questions are for, in the regulator's language, is AUSTRAC customer due diligence. The list of matters is customer due diligence requirements. How an existing relationship is watched is ongoing customer due diligence. The sector map is /tranche-2.

Banks were in the regime first

Banks, and other businesses in what people call Tranche 1, have been reporting entities for years. Their obligations were updated from 31 March 2026. A form that feels new in 2026 can be that update, or it can be the bank applying the same duty to a payment that looks unusual. AUSTRAC requires initial customer due diligence before a designated service, including identity, the people behind an entity, whether anyone is a politically exposed person or designated for sanctions, and the nature and purpose of the relationship. Source of funds and source of wealth are required in particular higher-risk cases. A bank asking those things is doing the list. It is not announcing a finding.

NAB is a bank. So are the others. This page has not seen the questions on your screen and will not pretend one institution's script is unique. If the questions are about a large transfer, a new payee, or a company account, they are still customer due diligence. If you are a small firm, your clients will receive the same sorts of questions from their bank when money moves for a settlement. That does not mean you lodge the bank's report, and it does not mean the bank has completed your customer due diligence for a designated service you provide.

How to answer without making it worse

  • Answer the question asked. Who owns the account, what the payment is for, and where the money came from, if that is what they asked.
  • Use records you have. A contract, a settlement statement, an invoice. Do not invent a cleaner story.
  • Do not ask “have you reported me?”. If they had a reporting question, tipping off would stop them telling you. Asking it does not help the payment.
  • Do not ignore it and complain on a forum. The bank can decline the service if it cannot complete customer due diligence.
  • Do not treat their form as your firm's program. If you are a reporting entity, you still do your own file.

A bank form beside your own duties. This table does not describe any bank's script.

SituationWhat it usually isWhat it is not
Questions on a personal accountThe bank's customer due diligenceA court finding
Questions on a company accountThe bank wanting the people and the purposeYour accountant's KYB, already done
A delay on a settlement paymentThe bank not yet satisfiedProof that a report was lodged
Your firm is a reporting entity tooA separate file you still keepA reason to copy the bank's PDF and stop

If you are the customer, answer in writing and keep a copy of what you sent. If you are the professional whose client was asked, do not complete the bank's form as if it were your own customer due diligence, and do not tell the client the questions mean a report exists. You do not know that. The bank will not tell you. Your help, if you give any, is to point at documents the client already has: the contract, the invoice, the settlement statement. Inventing a smoother story for the bank is not a professional courtesy. It is a new fact on a file that may later be yours as well, if you provide a designated service on the same matter.

Where this page stops

This page is the bank's question. It is not a script for your own clients, which is how to talk about AML with clients.

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. FreeAML does not answer a bank's questionnaire. If your firm needs its own check, the client pays that check.

Frequently Asked Questions

The bank's questions are the bank's program. Yours start only if you provide a designated service.

The firm suite is A$0. The client pays KYC or KYB for your file, not for the bank's.

Open the Tranche 2 guide

Questions: team@freeaml.com.au