---
title: "Enhanced customer due diligence decision record"
url: "https://ailawframework.com/precedents/aml-ctf-the-practice-as-a-reporting-entity/enhanced-cdd-decision-record"
type: "precedent"
site: "AI Law Framework"
id: "a52ob-enhanced-cdd-decision-record"
area_id: "A52OB"
kind: "form"
ai_level: "red"
version: 1
task_ids: ["A52OB-X20260927-4", "A52OB-X20260927-3"]
law_stated_as_at: "2026-10-22"
---

# 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.

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

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

## Key facts

- Kind: Form. A form to complete, or a guide to completing an official one.
- 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: 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: 2026-10-22
- Status: Maintained. Checked on 2026-10-22 against the 5 authorities it cites, for Australia.

## 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](https://ailawframework.com/obligations/aml-ctf-the-practice-as-a-reporting-entity/decide-and-record-enhanced-due-diligence-on-a-higher-risk-client.md)
- [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

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.

## Authorities

- [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)
- [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 123 (tipping off)](https://www.austlii.edu.au/cgi-bin/viewdoc/au/legis/cth/consol_act/alacfa2006522/s123.html)
- [AUSTRAC, Tipping off (s 123, customer management, scripts and genuine reasons)](https://www.austrac.gov.au/industry-and-business/obligations-and-guidance/your-amlctf-program/reporting-us/tipping-off)
- [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/enhanced-cdd-decision-record 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.*