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

Enhanced customer due diligence decision record

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.

Kind
Form. A form to complete, or a guide to completing an official one.
Where it applies
Australia
AI use
Red You write the text. The tool writes nothing into the document. Where permitted, it may check, clarify or collect data, and anything it checks or collects is verified.
Law stated as at
22 October 2026
Status
Maintained. Checked on 22 October 2026 against the 5 authorities it cites, for Australia.
Version
1
Source
Written for this library

When to use it

Complete before starting a designated service if a s 32 trigger is present, and again if a trigger appears during the matter and the practice proposes to continue. Do not use it to record the text of a suspicious matter report.

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

The compliance officer writes the trigger, the measures and the decision; a tool may only list KYC documents already on the file and any blank s 28(2) item.

AI may

  • List documents already saved on the file against the s 28(2) items, without commenting on authenticity.
  • Show which fields on this form are still blank.

AI must not

  • Must not decide that enhanced due diligence applies, or that it does not.
  • Must not draft the suspicion narrative or the words to be said to the client.
  • Must not be given the contents of a suspicious matter report.

The lawyer checks

  • The trigger ticked is one of the s 32 limbs, checked against the section, not against a vendor score alone.
  • The measures are specific to this client and are practicable before the service starts or continues.
  • Anything to be said to the client has been checked against the tipping-off script and s 123.

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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