Posted April 21, 2020

Posted By Meghann Cannon

How to meet your AML/CTF client identification obligations during Covid-19

Prepared by Catherine Evans

Covid-19 is rapidly changing the way the world does business. For those of you who have AML/CTF obligations, you may be wondering how you can identify new and existing clients when you can no longer physically meet each other. 

Your AML/CTF obligations are outcome focused, which means they are fluid. How they are met is determined by a number of factors specific to your business structure, risk appetite and designated services. AUSTRAC has confirmed that alternative methods of identifying clients are available, and can include (when using primary photographic identity documents): 

  1. at the time of the meeting, viewing an original document via webcam, or
  2. before the meeting, receiving an image of the original document via email, portal or something similar and which is verified during the meeting. 

Before you change how you identify new and existing clients, it is important to review your policies and procedures to determine whether these also need updating. AUSTRAC will expect you to accurately document how you meet your AML/CTF obligations regardless of the changing economy. 

If you want to take advantage of these alternative identification methods, get in touch with us to update your AML/CTF policy and procedures.


Receive regular updates.