---
title: "Customer due diligence file index before the service starts"
url: "https://ailawframework.com/precedents/aml-ctf-the-practice-as-a-reporting-entity/cdd-file-contents-index"
type: "precedent"
site: "AI Law Framework"
id: "a52ob-cdd-file-contents-index"
area_id: "A52OB"
kind: "checklist"
ai_level: "green"
version: 1
task_ids: ["A52OB-X20260927-3"]
law_stated_as_at: "2026-10-22"
---

# 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.

Canonical page: https://ailawframework.com/precedents/aml-ctf-the-practice-as-a-reporting-entity/cdd-file-contents-index  
Law stated as at: 2026-10-22

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

## Key facts

- Kind: Checklist. Steps or checks to work through and tick off.
- Practice area: [AML/CTF — the practice as a reporting entity](https://ailawframework.com/precedents/aml-ctf-the-practice-as-a-reporting-entity.md)
- Jurisdictions: Australia
- AI level: 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: 2026-10-22
- Status: Maintained. Checked on 2026-10-22 against the 3 authorities it cites, for Australia.

## 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

- [Assemble the customer due diligence record before the service starts](https://ailawframework.com/obligations/aml-ctf-the-practice-as-a-reporting-entity/assemble-the-customer-due-diligence-record-before-the-service-starts.md)

## 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.

## Authorities

- [Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) s 28 (initial customer due diligence before a designated service starts)](https://www.austlii.edu.au/cgi-bin/viewdoc/au/legis/cth/consol_act/alacfa2006522/s28.html)
- [Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) s 32 (enhanced customer due diligence)](https://www.austlii.edu.au/cgi-bin/viewdoc/au/legis/cth/consol_act/alacfa2006522/s32.html)
- [AUSTRAC, Record keeping overview (program records, CDD records, retention periods)](https://www.austrac.gov.au/industry-and-business/obligations-and-guidance/your-amlctf-program/develop-your-amlctf-programs/record-keeping/record-keeping-overview)

## Full text and drafting notes

The full text and the drafting notes are not part of this public page. Signed-in firm accounts can read them at https://ailawframework.com/precedents/aml-ctf-the-practice-as-a-reporting-entity/cdd-file-contents-index and through the signed-in MCP connector https://ailawframework.com/mcp/firm.

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