Customer Identification
The First Step: Verifying Identity Before the Transaction Begins
Customer Identification is your first line of defence against financial crime. Under the 2026 AUSTRAC reforms, real estate agents, lawyers, and accountants are legally required to verify the identity of their clients before providing a designated service. You cannot legally open a file, accept funds, or begin a transaction until this initial identification process is complete.
The Three Levels of Initial Verification
Your custom AML/CTF Program must explicitly outline how your staff will verify different types of clients during the onboarding phase:
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Individual Verification (Standard ID Checks): You must verify the client's Full Name, Date of Birth, and Residential Address. This can be done via Electronic Verification (matching client data against secure databases) or Manual Verification (collecting original or certified copies of a Primary Photo ID like a Passport or Driver Licence).
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Corporate & Trust Verification: For non-individual clients, you must look beyond the corporate veil. This means verifying the company’s registration with ASIC to ensure the entity is legally active and legitimate.
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High-Risk Onboarding: When a new customer is flagged as "High Risk" at the door (e.g., they operate through complex offshore trusts or are a foreign Politically Exposed Person), standard ID checks are not enough. You must gather additional information before senior management approves the onboarding.
How AML Partners 360 Helps
You shouldn't have to guess if your staff are collecting the right documents at the start of a matter. Our fixed-fee implementation packages include ready-to-use Customer Identification forms and staff checklists, ensuring your front-of-house team collects the legally required documents correctly on the very first try.