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
- Decide and record enhanced due diligence on a higher-risk client
- Assemble the customer due diligence record before the service starts
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.
Read the full text
The full text is available after you log in. It is free. When you log 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
- AUSTRAC enrolment form for a reporting entity
- Independent evaluation of the practice AML/CTF program
- ML/TF risk assessment record for a legal practice
- Designated services capture map and enrolment decision record (AML/CTF Act s 6(5B), table 6)
- First independent evaluation deadline for the practice
- AUSTRAC suspicious matter report
- Customer due diligence file index before the service starts
- Initial customer due diligence checklist for law practice designated services
- AUSTRAC legal professional privilege form for a report
- Legal profession AML/CTF program review triggers
- AI and automated tools in the AML/CTF program: control standard
- Deadline to notify AUSTRAC of the AML/CTF compliance officer
- AUSTRAC legal professional privilege form for a notice
- Tipping-off holding script for staff and the approved client note
- AML/CTF record retention schedule for the practice
- 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