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Verifying client identity

What counts as verification?

Collecting a client’s details is not the same as verifying them. Verification means confirming that the identity documents are genuine and belong to the person in front of you — using a reliable and independent method.

Acceptable verification methods include:

  • In person — inspect the original document at a meeting or open home, and confirm the photo matches the person
  • Video call — conduct a live video call where the client holds their document up to the camera; confirm the face and document match
  • Document Verification Service (DVS) — electronic matching against issuing authority records (available as an add-on on Professional, included on Agency)

AML Simple records which method was used, who performed the verification, and when.

Documents for individual clients

Collect one of the following primary photographic documents:

  • Australian driver’s licence
  • Australian passport
  • Foreign passport
  • State-issued proof of age card

If the client cannot provide a photographic document, you can use a primary non-photographic document (birth certificate, citizenship certificate, or Centrelink/DVA concession card) plus a secondary document such as a recent utility bill or ATO notice.

Record: document type, document number, issuing authority, and expiry date. You do not need to retain a copy of the document itself.

Documents for company clients

For a company client, collect:

  • ASIC company extract confirming the registered entity name, ACN, and registered address
  • Identity verification for the beneficial owners — individuals who own 25% or more of the company or who exercise effective control

Beneficial owners must be verified using the same individual identity standards above.

Enhanced due diligence triggers

Some clients require additional steps beyond standard CDD. Apply Enhanced CDD when:

  • The client is a foreign Politically Exposed Person (PEP) — a current or former senior politician, government official, military officer, or their close family or associates from another country
  • The client is from a high-risk jurisdiction on the FATF grey or black list
  • The transaction involves complex ownership structures with no clear legitimate purpose
  • Your risk assessment flags the client or transaction as high risk

Enhanced CDD requires senior management approval to proceed with the relationship, verification of the source of funds, and closer ongoing monitoring. Record these steps in the client record in AML Simple.

Marking verification as complete

Open the client record, go to the Verification tab, and select the verification method used. Enter the document details and the date. Save the record — the CDD status will update to Complete.

A client’s CDD status must be Complete before you mark a transaction as fully processed in AML Simple.