Decide and record enhanced due diligence on a higher-risk client
Key facts
- Human involvement
- YellowClose supervision
- How AI is used
- Assemble the indicators the file actually shows — the entity structure, the countries involved, the payment route, the pattern against the practice's risk assessment — into a comparison the lawyer works from, then draft the additional-measures section of the record to the lawyer's decision on each measure.
- What the lawyer must review
- The lawyer decides whether the file is higher risk and which measures apply; a rating the tool produced is an input, never the decision. Source of funds and source of wealth must be verified against documents — the client's explanation on its own is not verification. If the measures cannot be completed, the question becomes whether to act at all, and that belongs to the senior manager named in the policies.
- Written for / version
- US
Open a jurisdiction version of this task to see which instruments apply: US
Who does what
| Role | What they do |
|---|---|
| Assistance | Assemble the indicators the file actually shows — the entity structure, the countries involved, the payment route, the pattern against the practice's risk assessment — into a comparison the lawyer works from, then draft the additional-measures section of the record to the lawyer's decision on each measure. |
| Lawyer | Set the scope, supervise the work closely, verify every part relied on, resolve omissions and exceptions, and approve the exact output. |
Checklist
- Confirm the higher-risk trigger is one the practice's policies actually name — politically exposed person, higher-risk country, opaque structure, unusual payment route — and record which one.
- Verify source of funds and source of wealth against documents, and record which document supports which figure.
- Check every additional measure the policies require for this trigger has been applied and its result recorded, including the measures you decided not to apply and the reason.
- Screen the customer, the beneficial owners and the persons instructing, and record the date and the list used.
- Record the senior manager's approval to act, or the decision to decline or terminate, before the next step is taken on the file.
Forms and precedents for this task
| Form or precedent | Kind | AI use | Summary |
|---|---|---|---|
| Enhanced customer due diligence decision record | Form | AI use 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. |
Signed-in accounts can read the full text of each one. All precedents.
Sources
- AUSTRAC: Overview of customer due diligence reform · 2026-09-27
- AUSTRAC: Risk insights and indicators of suspicious activity — legal professionals · 2026-09-27
- Law Institute of Victoria: Ethical obligations in complying with the AML/CTF regime (11 December 2025) · 2026-09-27
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.