---
title: "Initial customer due diligence checklist for law practice designated services"
url: "https://ailawframework.com/precedents/aml-ctf-the-practice-as-a-reporting-entity/cdd-onboarding-checklist"
type: "precedent"
site: "AI Law Framework"
id: "a52ob-cdd-onboarding-checklist"
area_id: "A52OB"
kind: "checklist"
ai_level: "green"
version: 1
law_stated_as_at: "2026-10-17"
---

# 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…

Canonical page: https://ailawframework.com/precedents/aml-ctf-the-practice-as-a-reporting-entity/cdd-onboarding-checklist  
Law stated as at: 2026-10-17

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

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.

## 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. AI can do most of the drafting. A lawyer still reviews the result.
- Law stated as at: 2026-10-17
- Status: Maintained. Checked on 2026-10-17 against the 7 authorities it cites, for Australia.

## 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).

## Authorities

- [Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) s 28 (initial customer due diligence)](https://www.legislation.gov.au/C2006A00169/latest/text)
- [Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) ss 30, 31 and 32 (ongoing, simplified and enhanced customer due diligence)](https://www.legislation.gov.au/C2006A00169/latest/text)
- [Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) ss 35A, 37, 37A and 38 (credit reporting body verification; agents; reliance)](https://www.legislation.gov.au/C2006A00169/latest/text)
- [Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) s 111 (retention of CDD records for 7 years)](https://www.legislation.gov.au/C2006A00169/latest/text)
- [Anti-Money Laundering and Counter-Terrorism Financing Rules 2025 (Cth)](https://www.legislation.gov.au/F2025L01026/latest)
- [AUSTRAC, Overview of customer due diligence](https://www.austrac.gov.au/industry-and-business/obligations-and-guidance/your-amlctf-program/customer-due-diligence/overview-customer-due-diligence)
- [AUSTRAC, Money laundering update 2026 (artificial intelligence: identity fabrication, impersonation and fake documents)](https://www.austrac.gov.au/industry-and-business/education-and-resources/publications-and-resources/money-laundering-update-2026)

## Official form

[Official form](https://www.austrac.gov.au/industry-and-business/obligations-and-guidance/your-amlctf-program/customer-due-diligence/overview-customer-due-diligence)

## 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-onboarding-checklist 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.*