Are periodic reviews after settlement relevant for conveyancers?
Ongoing CDD applies even after a transaction settles where the firm continues to hold the customer on its books; easyAML automates re-screening and risk-rating refreshes.
Under AUSTRAC's ongoing CDD obligations, a customer relationship doesn't end the moment the matter completes. If you continue to hold the customer on your books (which conveyancers often do - many clients are repeat purchasers, sellers or referrers), you have an ongoing obligation to keep their KYC information current, re-screen them periodically, and respond to any new risk signals.
What easyAML automates:
- Re-screening cadence by risk rating - low risk re-screened annually, medium 6-monthly, high quarterly. PEP, sanctions and adverse-media checks re-run automatically.
- Re-screening cadence by activity - whenever a client re-engages for a new transaction with you - we automatically re-run PEP, sanctions and adverse-media checks
- ARNECC alignment - KYC is treated as valid for 2 years, after which a fresh KYC is required for the next property transaction.
- Structural change detection - for company / trust customers, ASIC change monitoring flags director or shareholder changes.
- CO notifications - fresh hits and material changes trigger an in-platform alert and an email to the Compliance Officer.
The conveyancer doesn't need to set up review schedules manually - the cadence is derived from the customer's risk rating, which the platform calculates from the Risk Assessment and per-transaction inputs. See AUSTRAC's Overview of customer due diligence.
For the customer-facing summary of when an AML Program should be reviewed (annual cycle, immediate-review triggers, mandatory three-yearly independent review), see HubSpot KB: https://knowledge.easyaml.com/when-should-i-review-my-aml-program
Related articles
- easyAML (Platform) Set-up Checklist
- Glossary: Key Terms & Definitions
- Pre-commencement customers - what CDD obligations apply, and the risks of not completing initial CDD
- How does CDD work for an off-the-plan purchase where settlement is years away?
- Does the platform automatically determine the customer's risk rating?