Client verification Current
Verifying a document meets your record-keeping requirements before filing it
A practical pre-filing check, not a copy of the document.
What you file isn't the document itself so much as the record of what you checked and how. This guide sets out a practical pre-filing check. It is general information, not legal or compliance advice.
Action plan
1 Confirm the record captures what was checked, not just a copy AUSTRAC doesn't require keeping the document itself -- it requires a record of what was checked.
AUSTRAC's guidance is clear that firms aren't required to keep scanned copies or photocopies of identity documents themselves. Instead, the record needs to show what you did to identify the customer and what information they provided, for example the details of the document used, rather than a copy of the document.
- Check the record states which document or data source was used, not just a scanned copy of it
- Check the record captures the relevant details from the document (type, number, issuer)
- Where a copy is kept for another reason, don't treat the copy alone as satisfying this record
Done when: The record captures the details of what was checked, not only a copy of the document
AUSTRAC: initial CDD for individuals2 Confirm the record is reasonably necessary and sufficient The record should be enough to show compliance and reconstruct the verification, not the bare minimum.
AUSTRAC's guidance describes the standard for these records as reasonably necessary to show you're meeting your customer due diligence obligations, and sufficient to reconstruct what was done. Before filing, check the record would actually let someone else understand what was verified and how.
- Check the record would let someone else reconstruct what was verified and how
- Check the record is complete and accurate, not a placeholder to fill in later
- Keep the record in its original format rather than converting it to another file type
Done when: The record is confirmed reasonably necessary and sufficient to demonstrate compliance before filing
AUSTRAC: record keeping overview3 Store and retain the record appropriately Sensitive verification records need secure storage and a clear retention period.
Once confirmed, store the record securely with access limited to authorised staff, and retain it for your firm's applicable retention period rather than treating filing as a one-off task with no ongoing responsibility.
- Store the record securely with access limited to authorised staff
- Apply your firm's documented retention period for customer due diligence records
- Confirm the record is retrievable, not just stored
Done when: The record has been stored securely and retained according to your firm's retention policy
See how structured intake and review works