--- title: "💼 FAQ: Customer Due Diligence for Individuals | Realaml Help Center" description: Realaml Knowledge Base --- [Skip to content](https://help.realaml.com/knowledge-base/faq-customer-due-diligence-for-individuals-realaml-help-center#main-content) ![6303e989](https://help.realaml.com/hs-fs/hubfs/6303e989.png?width=100&height=68&name=6303e989.png) Open main navigation Close main navigation How can we help you? - There are no suggestions because the search field is empty. 1. [Realaml Knowledge Base](https://help.realaml.com/knowledge-base?hsLang=en) 2. [Australia](https://help.realaml.com/knowledge-base/australia?hsLang=en) # 💼 FAQ: Customer Due Diligence for Individuals | Realaml Help Center ### 💼 FAQ: Customer Due Diligence for Individuals For Australian Law Firms – Let's clarify the compliant steps to verify an individual customer from July 1, 2026. ![](https://help.realaml.com/hubfs/Knowledge%20Base%20Import/JORDAN_HEADSHOT_2025-1741884224-Apr-29-2026-05-29-08-7014-AM.png) Written by Jordan ### 🧠 Background On March 27, 2025, during the [ACAMS-AUSTRAC webinar](https://www.acams.org/en/chapters/apac/acams-australasian-chapter-march-2025-virtual-event-acams-austrac-outreach), **Realaml** CEO **[Jordan Leroy McCown](https://www.linkedin.com/in/jordan-leroy-mccown-7b87487/)** asked: ​ *“In New Zealand, remote KYC requires both electronic confirmation of identity information and ensuring the person being onboarded can be matched to that identity — often through biometric or similar mechanisms. Given AUSTRAC’s Tranche 2 guidance is still evolving, why is there no reference to a mechanism for linking the person to the claimed identity, such as biometrics?”* ​ **AUSTRAC’s** **[Ashlea McKenzie](https://www.linkedin.com/in/ashlea-mckenzie-8aa146143/)** (Acting Director, Rules Reform) responded: ​ *“...Under the Act, where the customer is an individual, there is a requirement to take steps to establish that the customer is the person the customer claims to be... ​ So there is an explicit requirement, for individuals only, and that's in the Act...”* This requirement is reiterated by AUSTRAC and the Attorney-General’s Department: - 🔗 [AUSTRAC’s customer identification guidance](https://www.austrac.gov.au/business/core-guidance/customer-identification-and-verification): *“An individual customer is who they claim to be.”* - 🔗 [AGD AML reform summary](https://www.ag.gov.au/crime/anti-money-laundering-and-counter-terrorism-financing/anti-money-laundering-and-counter-terrorism-financing-amendment-act/changes-customer-due-diligence): *“In the case of customers who are individuals, take reasonable steps to establish that the customer is who they claim to be.”* 🔗 [AUSTRAC’s customer identification guidance](https://www.austrac.gov.au/business/core-guidance/customer-identification-and-verification): *“An individual customer is who they claim to be.”* 🔗 [AGD AML reform summary](https://www.ag.gov.au/crime/anti-money-laundering-and-counter-terrorism-financing/anti-money-laundering-and-counter-terrorism-financing-amendment-act/changes-customer-due-diligence): *“In the case of customers who are individuals, take reasonable steps to establish that the customer is who they claim to be.”* ### What does this mean for Australian law firms? You must go beyond simply collecting identity documents or verifying identity information. ​ To meet your customer due diligence obligations, law firms must: ​ ✅ Verify that the identity exists and is valid, **and** ✅ Take steps to confirm that the person presenting the ID is the person to whom it belongs. ### ❓Does this apply only to remote clients? **No.** This requirement applies to **all individual customers**, regardless of whether the onboarding is remote or face-to-face. ​ However, the method of verification should reflect: ​ 🔹 The customer’s money laundering or terrorism financing (ML/TF) risk, and 🔹 The channel of engagement (e.g., remote vs. in-person). ### ✅ Table of Compliant Methods These methods meet the requirement to confirm an individual is who they claim to be because they: - Verify the identity, and - Link the person to that identity. Verify the identity, and Link the person to that identity. **Tables can't be imported directly. Please insert an image of your table which can be found [here](https://442916559.hs-sites-ap1.com/knowledge-base/faq-customer-due-diligence-for-individuals-realaml-help-center?hsLang=en).** Method Verifies the ID? Links person to ID? Why it meets the requirement **Biometric liveness & facial matching** (selfie + ID) ✅ Yes ✅ Yes ID is authenticated; facial match confirms the person is alive and matches the ID **In-person face-to-ID sighting** ✅ Yes ✅ Yes Staff inspect the ID and confirm the photo matches **Secure video call with ID shown** ✅ Yes ✅ Yes Staff verify ID details and confirm match in real-time **Selfie upload + EIV match** ✅ Yes ✅ Yes Electronic ID verification + biometric facial match **Certified ID & third-party attestation** ✅ Yes ✅ Yes Referee certifies identity; must be recent and documented **Hybrid: EIV + live call/email/video** ✅ Yes ✅ Yes EIV confirms ID; verbal/video interaction links it to the person ### ❌ Table of Non-Compliant or Insufficient Methods These methods may confirm that an identity exists but do **not** prove who is using it — meaning they fail to meet the requirement to link the person to the claimed identity.. **Tables can't be imported directly. Please insert an image of your table which can be found [here](https://442916559.hs-sites-ap1.com/knowledge-base/faq-customer-due-diligence-for-individuals-realaml-help-center?hsLang=en).** Method Why it’s not sufficient **EIV alone (no selfie/liveness)** Doesn’t link the person to the ID **Stored photo ID (no face check)** No way to know who submitted it **Document authentication only** Doesn’t confirm presenter **“We know them” / prior relationship** Does not constitute identity verification ### 🤖 Is biometric verification required? **Not explicitly — but functionally yes, in many remote onboarding scenarios.** ​ Without biometrics or another mechanism for linking the person to their ID, it is difficult for law firms to satisfy that an individual customer is who they claim to be. ### 👤 What if the person is already known to us? That’s **not enough**. ​ Even if you have a prior relationship with the client, you must still complete identity verification in accordance with the Act — unless an explicit exemption applies. ### ⏳ Can law firms delay verification? **No — not under normal circumstances.** ​ From 1 July 2026, under Section 28(1) of the AML/CTF Act, Australian law firms that are captured as reporting entities must verify a customer’s identity before providing any designated service under Tranche 2 (e.g., conveyancing, forming companies, managing client funds — subject to final rules). ​ Some industries may seek exemptions (e.g., auction-day real estate buyers), but **no such exemption currently applies to legal practitioners**. ​ **If AUSTRAC introduces any exemptions in the future, law firms must:** - Clearly document the exemption in their AML/CTF Program, and - Complete verification as soon as practicable, with no suspicion arising during the delay. Clearly document the exemption in their AML/CTF Program, and Complete verification as soon as practicable, with no suspicion arising during the delay. ### ⚖️ What happens if we don’t comply? - Failing to comply with Section 28(1) is a **civil penalty provision** - Each unverified onboarding can count as a **separate breach** - Your firm must document your customer due diligence (CDD) approach and justification within your **AML/CTF Program** Failing to comply with Section 28(1) is a **civil penalty provision** Each unverified onboarding can count as a **separate breach** Your firm must document your customer due diligence (CDD) approach and justification within your **AML/CTF Program** ### 🔹 AUSTRAC Resources - [AUSTRAC Reform Hub](https://www.austrac.gov.au/about-us/amlctf-reform) - [Draft AML/CTF Rules – Exposure 1](https://www.austrac.gov.au/sites/default/files/2024-12/Exposure%20Draft%20AMLCTF%20Rules.pdf) - [AUSTRAC Customer Identification & Verification](https://www.austrac.gov.au/business/how-comply-and-report-guidance-and-resources/customer-identification-and-verification) - [Attorney-General’s Department – CDD Reform Summary](https://consultations.ag.gov.au/crime/reforming-aml-ctf-financing-regime/) [AUSTRAC Reform Hub](https://www.austrac.gov.au/about-us/amlctf-reform) [Draft AML/CTF Rules – Exposure 1](https://www.austrac.gov.au/sites/default/files/2024-12/Exposure%20Draft%20AMLCTF%20Rules.pdf) [AUSTRAC Customer Identification & Verification](https://www.austrac.gov.au/business/how-comply-and-report-guidance-and-resources/customer-identification-and-verification) [Attorney-General’s Department – CDD Reform Summary](https://consultations.ag.gov.au/crime/reforming-aml-ctf-financing-regime/) This FAQ is based on available guidance as of March 2025. 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