Client intake Current

Requesting identity documents from an individual client

A practical checklist for collecting identity evidence before you start providing a service.

Firms with customer due diligence obligations generally need to identify an individual client before providing them with a designated service. This guide sets out a practical approach to requesting that evidence. It is general information, not legal or compliance advice.

Action plan

1 Explain why you are asking Tell the client up front why identity evidence is needed and how it will be used.

Clients generally respond better to identity requests when they understand the reason. A short, plain explanation that identity verification is a standard part of your firm's onboarding process for a matter like theirs, and that the documents will be kept securely, generally reduces friction and follow-up questions.

  • Explain that identity verification is a standard part of your firm's onboarding process, not a one-off suspicion
  • Explain what will happen to the documents once received
  • Give the client a clear, short list of exactly what is needed

Done when: The client has been told why identity documents are required and what will happen to them

AUSTRAC: overview of customer due diligence
2 Request primary and secondary identification Ask for one form of government-issued photo identification, plus a secondary document.

Exactly which document combinations satisfy your firm's own customer due diligence procedure is set out in your firm's AML/CTF program, not by Vertical Flows. A common practical approach is one current government-issued photo identification document (for example a driver licence or passport) plus a secondary document that confirms name and residential address (for example a recent utility bill or bank statement).

  • Ask for one current government-issued photo identification document
  • Ask for a secondary document that confirms name and address
  • Confirm against your firm's own AML/CTF program what combination it requires

Done when: The client has provided a primary photo identification document and a secondary document

AUSTRAC: overview of customer due diligence
3 Collect and verify before you start the service Complete initial identification before providing the designated service, not after.

AUSTRAC's own guidance is clear that initial customer due diligence generally needs to be completed before a firm starts providing a designated service to that customer, with only limited, specific exceptions set out in AUSTRAC's guidance. Build identity collection into the very start of your intake process rather than treating it as a formality to finish later.

  • Sequence identity collection as the first step of intake, not a follow-up task
  • Do not begin substantive work before identity documents are received and verified
  • Check AUSTRAC's guidance directly if a genuine exception might apply to a specific matter

Done when: Identity documents are collected and verified before the designated service begins

AUSTRAC: overview of customer due diligence
4 Store the documents securely Keep identity evidence with your firm's other client due diligence records.

Once collected, identity documents should be stored with your firm's other customer due diligence records, with access limited to people who need it. Vertical Flows can structure the intake and evidence-storage workflow this relies on. It does not set your firm's record-keeping policy.

  • Store identity documents with your other client due diligence evidence
  • Limit who in your firm can access stored identity documents
  • Follow your firm's own retention and disposal policy

Done when: Identity documents are stored securely with access limited to authorised staff

See how structured intake and review works