Identifying customers who don’t have conventional forms of ID
Some of your customers may not be able to provide the identity documents you would usually rely on for applicable customer identification procedures. For example, they may not have a driver’s licence or a birth certificate, the information in their identification documents could be out of date, or there could be conflicting information in different documents. This might be the case for Aboriginal and Torres Strait Islander customers who live in remote areas, transgender customers, or customers who have come to Australia as refugees.
Without conventional forms of identification it may be hard for people to access financial services.
AUSTRAC recommends a flexible approach to identifying and verifying customers who don’t have conventional ID, while taking into account your own money laundering/terrorism financing risk profile. For example, you might use several types of secondary documents to establish a customer’s identity instead of a primary identification document.
Or you might choose to use alternative identification that is 'reliable and independent'.
Using alternative identification
While the AML/CTF Rules give guidance about what reliable and independent documentation can be, they do not provide a comprehensive list.
If you decide to use different identification to that listed in the Rules, for each customer you must:
- consider the money laundering/terrorism financing risk assessment you made of your own business or organisation
- undertake a risk assessment of both the customer and the transaction.
Flexible approach for Aboriginal and Torres Strait Islander customers
AUSTRAC recommends setting up protocols to identify and verify Aboriginal and Torres Strait Islander customers when you can’t rely on conventional identification and verification methods.
There might also be times when Aboriginal and Torres Strait Islander customers produce identification documents with conflicting information. For example, different government agencies may record different dates of birth for the same person, which makes it difficult to establish or verify their identity.
We recommend adopting a flexible approach while being mindful of social and cultural sensitivities. This might include using ‘reliable and independent’ means of alternative identification for Aboriginal and Torres Strait Islander customers such as:
- an Indigenous community identity card
- a reference from a community Elder
- a reference from a board member of a local Aboriginal Land Council or Aboriginal/ Torres Strait Islander organisation
- a government letter that shows the customer’s name.
These scenarios show how you can identify and verify Aboriginal and Torres Strait Islander customers who don’t have conventional forms of ID. These examples might help you consider how you can identify and verify other customers who don’t meet your usual customer identification requirements.
Example 1: Opening an account
Mr Acacia wants to open a credit union account, but doesn’t have the usual forms of identification that the credit union uses to verify a customer’s identity. Mr Acacia explains that he lives in a remote community and recently changed his name. The credit union assesses the money laundering/terrorism financing risk as low. It decides to use an alternative identification document and tells Mr Acacia it can accept a reference from an Elder of Mr Acacia’s community that confirms his name and address. The credit union reviews the reference Mr Acacia provides and completes the verification.
Example 2: Superannuation beneficiary
Ms Waratah has recently died and her daughter, Ms Banksia, is the beneficiary of Ms Waratah’s superannuation policy with Pine Super. However, Ms Banksia changed her name after her mother died and her full name is now different to the name originally recorded in the form nominating her as the beneficiary. Pine Super wants to be sure that Ms Banksia is really Ms Waratah’s daughter and asks for information about her name change.
Ms Banksia identifies as Aboriginal and tells Pine it’s customary not to use the name of a person who has died. She doesn’t have any official ID in her new name. She has provided her name and address to Pine, but doesn’t know her actual date of birth – only the year and where she was born.
Pine can’t verify Ms Banksia’s current name or date of birth, but assesses her money laundering/terrorism financing risk as low and decides to verify her identity with a reference from an acceptable referee. Ms Banksia tells Pine Super that her mother’s doctor is also her doctor and can provide a reference about their relationship. Pine Super uses the reference from the doctor to verify Ms Banksia’s identity.
Example 3: Conflicting identification documents
Mr Wattle wants to open a bank account and shows the bank a range of identification documents from government departments to prove his identity. But the documents have inconsistencies in Mr Wattle’s name and different dates of birth. Mr Wattle isn’t sure which birth date is accurate. The bank isn’t sure which document, if any, it can use to identify him.
The bank assesses the money laundering/terrorism financing risk and decides to accept an alternative document to verify Mr Wattle’s identity. It asks him for copies of the government documents and for a reference from the president of the local Aboriginal Land Council (ALC) which states that Mr Wattle is the person named in all the documents. The president provides a reference on ALC letterhead that includes a photograph of Mr Wattle. The bank uses this to verify Mr Wattle’s identity.
The content on this website is general and is not legal advice. Before you make a decision or take a particular action based on the content on this website, you should check its accuracy, completeness, currency and relevance for your purposes. You may wish to seek independent professional advice.