Client verification Current
Verifying a client's identity documents against a reliable source
A practical approach to checking identity evidence, not just collecting it.
Collecting identity documents is only the first step; a firm generally also needs to verify that information against independent and reliable data. This guide sets out a practical approach to that verification step. It is general information, not legal or compliance advice.
Action plan
1 Verify against independent and reliable data AUSTRAC's own guidance describes what counts as independent and reliable verification data.
AUSTRAC's guidance on initial customer due diligence for individuals describes independent and reliable data that can be used to verify identity information, and notes that for documents you can generally obtain either an original or a reliable copy of the document, or an extract from it. Whether a specific document or data source meets this standard for a given customer is a determination for your firm to make.
- Check the document or data source against your firm's own AML/CTF program criteria for independent and reliable verification
- Where a document is used, obtain an original or a reliable copy
- Note that expired documents may call for additional information
Done when: Identity information has been verified against independent and reliable data
AUSTRAC: initial CDD for individuals2 Cross-check documents against each other Consistency between documents is a useful practical check.
Where more than one document is provided, checking that names, dates of birth, and addresses are consistent across them is a practical way to catch simple errors or mismatches before relying on the documents.
- Compare name, date of birth, and address details across every document provided
- Follow up directly with the client on any mismatch before proceeding
- Document how the cross-check was performed
Done when: Details have been cross-checked for consistency across every document provided
See how structured intake and review works3 Record how verification was performed Keep a record of what was checked and how, not just the outcome.
AUSTRAC's guidance notes that firms are not required to keep the documents themselves under their record-keeping obligations and can instead record details of the documents. Recording which documents or data sources were used, and how they were checked, gives your firm evidence its verification process was followed.
- Record which documents or data sources were used to verify identity
- Record how the verification was performed and by whom
- Keep this record with your firm's other customer due diligence evidence
Done when: A record exists of the verification method used and the outcome
AUSTRAC: initial CDD for individuals