Checklist · AML/CTF — the practice as a reporting entity
Initial customer due diligence checklist for law practice designated services
Checklist for completing initial customer due diligence before a designated service starts: identity, beneficial owners, agents and authority, PEP and sanctions screening, nature and purpose, risk rating, enhanced measures, reliance, AI-assisted verification and records.
- Kind
- Checklist. Steps or checks to work through and tick off.
- Where it applies
- Australia
- AI use
- Green AI can do most of the drafting. A lawyer still reviews the result.
- Law stated as at
- 17 October 2026
- Status
- Maintained. Checked on 17 October 2026 against the 7 authorities it cites, for Australia.
- Version
- 1
- Source
- Written for this library
When to use it
Use at file opening for every matter the capture map marks as a designated service, before the service starts (subject to any delay the AML/CTF Rules permit, for example for some conveyancing buyers). Use the practice's AML/CTF program forms where they differ.
How AI may be used
Bounded assistance. AI can populate the CDD record from the identity documents, extracts and engagement papers the lawyer has collected and list every field without a source, but the lawyer verifies, rates and decides.
AI may
- Extract names, dates of birth, addresses, ACN or ABN and the ownership and control chain from documents already collected into the CDD record.
- Rate the file against the fixed factors in the practice's policies as a suggestion, and list every field with no source.
- Flag inconsistencies between documents (names, dates, addresses, signatures).
AI must not
- Must not be the sole basis for verifying identity or authenticity of documents.
- Must not finalise a risk rating, decide on enhanced due diligence, or discount a sanctions or PEP match.
- Must not be used to tell the client why further information is needed once a suspicion has formed.
The lawyer checks
- Verification used reliable and independent data appropriate to the risk, and the method is recorded.
- The risk rating and any enhanced measures are the lawyer's decision, with reasons.
- The record is complete before the designated service starts (or within any permitted delay).
Method: how the Green, Yellow and Red levels are decided. This is guidance for planning, not legal advice.
Official form
Open the official form. Always use the current version from the issuer.
Read the full text
The full text is for signed-in accounts. It is free. When you sign in you can:
- read the whole precedent, with its drafting notes beside it;
- copy it, or download it as a Word file or Markdown;
- add it to your firm’s knowledge base, so colleagues can find it;
- let the AI tools you connect read it from that knowledge base.
The summary, the law it rests on and the AI-use guidance above stay public. Privacy.
More in AML/CTF — the practice as a reporting entity
- AML/CTF program for small legal practices: AUSTRAC legal profession starter kit adoption guide
- Designated services capture map and enrolment decision record (AML/CTF Act s 6(5B), table 6)
- AI and automated tools in the AML/CTF program: control standard
- Suspicious matter escalation, reporting and legal professional privilege procedure
- Client letter: why we need to verify your identity (AML/CTF obligations)
All precedents for AML/CTF — the practice as a reporting entity · Tasks and AI use in this area