AUSTRAC Tranche 2 is live from 1 July 2026. Accountants, lawyers and real estate agents must comply. Get compliant now

CDD Requirements Australia 2026

Customer Due Diligence Requirements

What CDD means under Australian law and what you must do at each stage of your client relationship.

Initial CDD

Must be completed before you provide any designated service. Includes identity verification, beneficial ownership checks and risk rating.

✓Verify client identity
✓Identify beneficial owners
✓PEP and sanctions screening
✓Verify nature and purpose of relationship
✓Assign Low/Medium/High risk rating

Ongoing CDD

Continue monitoring clients throughout your relationship. Frequency depends on risk rating.

✓High risk - periodic review every 12 months
✓Medium risk - periodic review every 2 years
✓Low risk - periodic review every 3 years
✓Monitor for unusual activity continuously

Enhanced CDD

Required for high-risk clients and before submitting a suspicious matter report.

✓Adverse media check
✓Source of funds verification
✓Source of wealth verification
✓Senior manager approval required

Pre-Commencement CDD

Lighter CDD for clients already receiving services on 1 July 2026.

✓Monitor for changes in risk
✓Full CDD required if new designated service requested
✓Full CDD required if SMR submitted

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