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Customers without standard ID

AUSTRAC recognises some of your customers might not have standard identification.

 How to do this in easyAML 

  1. Open an In-person VOI

    Navigate to the client's profile and begin a new Verification of Identity. Make sure you are conducting this in person - the additional document option is not available for remote VOIs.

  2. Select "Additional document"

    During the VOI, you will see an option to add an additional document. Select this when the client cannot provide standard identification and one of the alternative documents below is available.

  3. Upload the alternative document/s

    Photograph or upload the document within the VOI flow. Any of the alternative document types listed above can be uploaded here.

  4. Document your reasoning

    Record in your the KYC's Notes why standard identification was not available, which alternative document you accepted, and the steps you took to assess the ML/TF risk. AUSTRAC requires this record-keeping as part of your alternative identification procedures.

The alternative document categories from AUSTRAC's guidance are:

Alternative ID options (AUSTRAC)

  • Referee statement
  • Government correspondence
  • Recently expired ID
  • Community/organisation membership card (First Nations)
  • Self-attestation (last resort only)

Which persons does this apply to

  • First Nations peoples (inconsistent documents)
  • Natural disaster affected
  • Domestic violence affected
  • Recently released from prison
  • Trans & gender diverse customers
  • Individuals in remote areas with limited document access

One compliance note to keep in mind: AUSTRAC expects you to document your reasoning when using alternative ID specifically why standard documents weren't available and how you assessed the ML/TF risk. easyAML's record of the uploaded document supports this, but you should also add a note within their KYC record.

 

Related: My client couldn't be verified electronically and Birth certificate troubleshooting tips.