AML/CTF customer due diligence checklist
From 1 July 2026 law firms are reporting entities under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 for designated services. This checklist is for firms preparing CDD processes under Tranche 2.
This is a 12-step customer due diligence checklist for Australian law firms under the AML/CTF regime. It covers identification, verification, beneficial ownership, and ongoing monitoring.
The checklist
Identify designated services
Confirm whether the client is receiving a designated service triggering CDD.
Collect client identity
Collect full name, residential address, and date of birth for individual clients.
Verify identity
Verify identity against reliable documents — passport, driver licence, Medicare.
Identify legal structure
For companies, trusts, or partnerships, identify the legal structure and controlling parties.
Identify beneficial owners
Identify all beneficial owners holding 25% or more of the entity.
PEP screening
Screen client and beneficial owners against politically exposed persons lists.
Sanctions screening
Screen against Australian and UN sanctions lists.
Assess risk
Assess ML/TF risk rating based on client, service, geography, and channel.
Apply enhanced CDD where required
For high risk clients, apply enhanced customer due diligence including source of funds.
Document CDD findings
Document the CDD findings and risk rating in the client file.
Ongoing monitoring
Monitor the relationship for unusual transactions and periodic re-verification.
Report suspicious matters
Report suspicious matter reports to AUSTRAC within the statutory deadline.
When this checklist applies
Use at client onboarding and throughout the matter life cycle for any AML/CTF designated service.
Common pitfalls
- Missing beneficial owner identification for trusts
- PEP screening not refreshed
- Risk assessment not documented
- Source of funds not verified for high risk
- Suspicious matter reports missed
Run this checklist on a real matter
Quillio can run CDD checks, generate risk ratings, and produce audit-ready CDD files. See /practice-areas/firm-management or start a free trial.
General guidance for AML/CTF CDD. Apply the AML/CTF Rules and AUSTRAC guidance current at the time.
Use this checklist on your matter.
Quillio can run this checklist on a specific NSW conveyancing matter — confirm each item, calculate adjustments, and generate the supporting documents. The free trial requires no credit card.
Start your free trial