Checklist · AML/CTF — the practice as a reporting entity

Customer due diligence file index before the service starts

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.

Kind
Checklist. Steps or checks to work through and tick off.
Where it applies
Australia
AI use
Green The tool writes the first draft inside a template you have already tested. You check it. Without that test, first drafting starts at Yellow.
Law stated as at
22 October 2026
Status
Maintained. Checked on 22 October 2026 against the 3 authorities it cites, for Australia.
Version
1
Source
Written for this library

When to use it

Use on each matter that is a designated service, before the service starts. It shows whether the file contains material for each s 28(2) matter. The compliance officer or the responsible lawyer still decides whether that material establishes the matters on reasonable grounds.

Used for these tasks

Each task page says how far AI may help with the task and what the lawyer must review.

How AI may be used

Inside this fixed index, an approved tool may enter the document title and date already saved on the file for each s 28(2) row, and the lawyer confirms the row before the service starts.

AI may

  • Enter the filename and date of a document already stored against the matching s 28(2) row.
  • Leave a row blank and mark it "no document on the file" when the file has none.
  • List rows that are still blank.

AI must not

  • Must not tick "established on reasonable grounds".
  • Must not treat a screening vendor's "pass" as verification under s 28(3)(d).
  • Must not start the designated service, or tell the client that it has started.

The lawyer checks

  • Each document named is the document on the file, and it relates to this client.
  • The reasonable-grounds column is completed by a person, for every row, before the service starts.
  • If a s 32 trigger is present, the enhanced due diligence decision record is attached and the service has not started ahead of it.

Method: how the Green, Yellow and Red levels are decided. This is guidance for planning, not legal advice.

Authorities

Read the full text

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