It is possible your business may face resistance from some customers who may not be willing to provide identification. This can be particularly difficult when you may have known a client for a long period of time, or where issues of trust and community loyalty come into play. As previously mentioned, identification requirements for customers who were receiving one of your designated services prior to 12 December 2007 may often be less stringent. You may wish to consider an awareness campaign notifying customers through signs, mail-outs, or your website that due to new legislative requirements customer identification procedures have changed. Public knowledge that your business is active in fighting terrorism and money laundering is likely to benefit your overall business through enhancing its reputation, credibility and market competitiveness.

If a reporting entity has reasonable grounds to believe a customer may have information that will help them to comply with their AML/CTF program, section 92 of the AML/CTF Act allows the reporting entity to request in writing such information within a specified time. During that time the AML/CTF Act allows you to restrict or limit designated services to the customer. For reporting entities concerned with any legal action taken against them regarding actions taken in good faith when exercising this power, additional protection from liability may be available under subsection 92(5) of the AML/CTF Act.