Does the platform require firms to identify each transaction's risk type for the right CDD flow?
No, the platform calculates the risk and tailors the CDD flow based on the transaction type, size, complexity, jurisidiction and sector configuration.
The platform calculates the risk and tailors the CDD flow based on the transaction type, size, complexity, jurisidiction and the firm's sector configuration. Two main flows currently:
- Real estate and conveyancing follow the ARNECC standard - 100-point identification with the specific document combinations ARNECC has approved (passport + secondary ID; or two from the secondary list including a photo ID, etc.). This is the long-established VOI standard for property transactions and underpins the 2-year ARNECC validity window.
- Other sectors (legal practitioners outside conveyancing, accountants, trust/corporate services, precious metals) use a single-document flow with appropriate biometric verification. This aligns with AUSTRAC's risk-based approach where the 100-point ARNECC framework isn't specifically required.
The flow is being refined to key off the transaction type rather than the account's sector setting - so a firm operating across multiple sectors gets the right CDD flow per transaction, not a one-size-fits-all flow based on the firm's primary sector. This is particularly relevant for multi-sector firms (e.g. a law firm that does both conveyancing and general legal work, or an accounting firm that also provides trust services).
What the firm does in practice: nothing manual. The platform reads the transaction context (matter type, sector, parties involved) and selects the right CDD flow automatically. Staff just initiate the transaction; the platform handles the flow selection.