---
title: "Assemble the customer due diligence record before the service starts"
url: "https://ailawframework.com/obligations/aml-ctf-the-practice-as-a-reporting-entity/assemble-the-customer-due-diligence-record-before-the-service-starts"
type: "task"
site: "AI Law Framework"
id: "A52OB-X20260927-3"
practice_area: "AML/CTF — the practice as a reporting entity"
tier: "green"
lawyer_review: "required"
last_reviewed: "2026-10-22"
---

# Assemble the customer due diligence record before the service starts

> From the identity documents, the company or trust extracts and the engagement papers the lawyer has collected, populate the practice's CDD record: extract names, dates of birth, addresses, ACN or ABN and the ownership…

Canonical page: https://ailawframework.com/obligations/aml-ctf-the-practice-as-a-reporting-entity/assemble-the-customer-due-diligence-record-before-the-service-starts  
Last reviewed: 2026-10-22

Site index for agents: https://ailawframework.com/llms.txt

## Key facts

| Fact | Value |
| --- | --- |
| Practice area | [AML/CTF — the practice as a reporting entity](https://ailawframework.com/obligations/aml-ctf-the-practice-as-a-reporting-entity.md) |
| Human involvement | Green: AI drafts, lawyer checks |
| How AI is used | From the identity documents, the company or trust extracts and the engagement papers the lawyer has collected, populate the practice's CDD record: extract names, dates of birth, addresses, ACN or ABN and the ownership and control chain from the extracts, rate the file against the fixed factors in the policies, and list every field the file holds no source for. |
| What the lawyer must review | Read each extracted detail against the document it came from, not against the summary: a transposed date of birth or a stale company extract is a verification failure, not a typo. The beneficial owners are the lawyer's determination — a discretionary trust, a nominee holding or an offshore layer will not resolve from an extract. Nothing is provided to the customer until the record is complete, unless the policies expressly allow it. |
| Written for / versions | 1 jurisdiction versions below |

## Checking plan

**Lawyer review required**

The responsible lawyer reviews the work against the instructions, sources and intended use.

- What the AI does: From the identity documents, the company or trust extracts and the engagement papers the lawyer has collected, populate the practice's CDD record: extract names, dates of birth, addresses, ACN or ABN and the ownership and control chain from the extracts, rate the file against the fixed factors in the policies, and list every field the file holds no source for.
- What the lawyer does: Read each extracted detail against the document it came from, not against the summary: a transposed date of birth or a stale company extract is a verification failure, not a typo. The beneficial owners are the lawyer's determination — a discretionary trust, a nominee holding or an offshore layer will not resolve from an extract. Nothing is provided to the customer until the record is complete, unless the policies expressly allow it.
- Who reviews: Responsible lawyer with competence in the matter
- Basis: Practical workflow informed by the linked primary sources; the traffic light and working checks are editorial guidance, not a court classification.
- Why: The level reflects what the work is, the consequence of an error, and how much of the output the lawyer must independently re-derive.

## Checks the lawyer makes

1. Check each extracted identifier character by character against its source document, and confirm the document is current and of a kind the policies accept.
2. Confirm the company or trust extract is dated within the period the policies allow and that the chain runs to individuals rather than stopping at another entity.
3. Determine the beneficial owners yourself where the chain does not resolve, and record how you reached the determination.
4. Verify the identity of every person giving instructions on the customer's behalf and record the authority they rely on.
5. Check the record is dated before the designated service was provided and that every field with no source is escalated to the compliance officer rather than left blank.

## Notes

- These are suggested working checks. Confirm the required checking with the responsible lawyer before work starts; the checking approach does not establish permission to use AI.

## Sources

- [AUSTRAC: Overview of customer due diligence reform](https://www.austrac.gov.au/about-us/amlctf-reform/reforms-guidance/amlctf-program-reform/customer-due-diligence-reform/overview-customer-due-diligence-reform) (checked 2026-09-27)
- [Law Institute of Victoria: Ethical obligations in complying with the AML/CTF regime (11 December 2025)](https://www.liv.asn.au/Common/Uploaded%20files/Knowledge-Hub/AML/20251211_AMLCTF_EthicalObligations_InformationSheet_Final.pdf) (checked 2026-09-27)
- [Law Society of NSW: AML/CTF Implementation Guide for sole practitioners and small practices](https://www.lawsociety.com.au/sites/default/files/2026-04/LS4839_PSU_AMLCTF_SmallGuide_2026-04-10a.pdf) (checked 2026-09-27)

## Forms and precedents for this task

| Form or precedent | Kind | AI level | Summary |
| --- | --- | --- | --- |
| [Enhanced customer due diligence decision record](https://ailawframework.com/precedents/aml-ctf-the-practice-as-a-reporting-entity/enhanced-cdd-decision-record.md) | Form | Red | Record of why enhanced customer due diligence applies to a client under s 32, the measures the compliance officer requires, and whether the practice will start or continue the designated service. |
| [Customer due diligence file index before the service starts](https://ailawframework.com/precedents/aml-ctf-the-practice-as-a-reporting-entity/cdd-file-contents-index.md) | Checklist | Green | Index of the s 28(2) matters against the documents on the file, completed before a designated service starts, so a missing identity, authority, beneficial owner or sanctions check is visible. |
| [AML/CTF record retention schedule for the practice](https://ailawframework.com/precedents/aml-ctf-the-practice-as-a-reporting-entity/aml-record-retention-schedule.md) | Policy | Yellow | Schedule of how long the practice keeps AML/CTF program records, customer due diligence records and transaction records, using the periods AUSTRAC states for ss 116, 111 and 107, and who may destroy… |

Signed-in accounts can read the full text of each one.

## Jurisdiction versions

| Jurisdiction | Level |
| --- | --- |
| [United States](https://ailawframework.com/obligations/aml-ctf-the-practice-as-a-reporting-entity/assemble-the-customer-due-diligence-record-before-the-service-starts/united-states.md) | Green |

*Practice guidance for planning and review. Confirm current primary sources and the requirements of the actual matter. This is general information, not legal advice.*