In most cases it will not be necessary to re-identify customers to whom you provided a designated service before 12 December 2007. These are referred to as 'pre-commencement customers'. An exception to this is where a customer's behaviour or transaction raises suspicion that would warrant your business lodging a suspicious matter report (SMR) to AUSTRAC. It is important to remember that it is unlawful to disclose to a customer that an SMR is being lodged. For more information about suspicious matter reporting, review the 'Reporting obligations' module of the AUSTRAC Introduction to AML/CTF e-learning course.

Requesting proof of identity from customers will be familiar to reporting entities who offered accounts and were required to verify customer information under the FTR Act by using the 100 point check or 'reference from an acceptable referee'. However, the AML/CTF Act broadens the range of services where customer identification is now required. Prior to 12 December 2007 your business may have provided certain services without the need to identify customers. Those customers who received a particular service before that time may not need to be identified now, however if they seek a designated service they were not previously using, then identification may be required.

Although existing customers will likely not be required to be identified, they will be subject to risk-based ongoing customer due diligence from 12 December 2008.

Customer identification ready reckoner (flash 1819kb)