For a buyer's agent with 50 recurring clients, do they need a fresh KYC each purchase?
No, not within the 2-year easyAML validity window, provided the underlying identity and risk profile have not materially changed; ongoing CDD keeps the picture current.
You can re-use the KYC within the 2-year easyAML validity window, provided the underlying identity and risk profile haven't materially changed. AUSTRAC's risk-based approach doesn't require duplicate identity verification where verified data is already on file and the customer's risk hasn't shifted; what it requires is ongoing CDD that keeps the picture current.
What this looks like in practice:
- First transaction. Full KYC - VOI with biometrics, PEP / Sanctions / Adverse-media screening, customer questionnaire. KYB if the client is purchasing through a company or trust.
- Subsequent transactions within 2 years. Reuse the existing KYC. The platform creates a new transaction record for the new property (log property details, settlement timing, parties) but skips the identity-verification step.
- Automatic re-screening. easyAML re-runs PEP, sanctions and adverse-media checks in the background - low risk annually, medium 6-monthly, high quarterly, and on each new transaction for transactional sectors. No additional fee.
- Trigger for fresh ECDD. A new PEP or sanctions hit, an ASIC change to a corporate buyer, a jurisdiction shift, a change in transaction profile, or any genuine suspicion. Where any of these fire, the platform flags it before the new matter can complete.
When a fresh KYC is required for a repeat client: the 2-year window has lapsed, the customer's risk rating has materially changed, identity details have changed (legal name change, new ID document), or suspicion has formed.
See AUSTRAC's Overview of customer due diligence and Ongoing customer due diligence pages.
Related articles
- easyAML (Platform) Set-up Checklist
- Does easyAML accept externally-provided VOI evidence (KYC done by another provider)?
- Glossary: Key Terms & Definitions
- Pre-commencement customers - what CDD obligations apply, and the risks of not completing initial CDD
- What's the difference between CDD, KYC and KYB - and when does each apply?