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How are repeat clients (e.g. property flippers, developers) handled - redo KYC for every property sale or settlement?

No, within the 2-year validity window the same individual's KYC can be reused for new transactions; PEP, sanctions and adverse-media re-screening still runs each engagement.

This aligns with the property settlement 2-year ARNECC validity period, the same individual's KYC can be reused for new transactions without redoing the identity verification step. This is the right outcome under AUSTRAC's risk-based approach - the underlying identity hasn't changed.

What still has to happen on each new engagement:

  • PEP, sanctions and adverse-media re-screening runs automatically against the existing customer name. PEP and sanctions lists change daily; the re-screen catches any new hits since the last engagement. easyAML does this at no extra charge.
  • Risk re-assessment for the new transaction. Even with the same customer, transaction-level inputs differ (counterparty, jurisdiction, value, purpose). The risk score is recalculated for the new matter.
  • ASIC change monitoring for company’s. If a director, shareholder or beneficial owner has changed since the last engagement, the platform flags the structural change before the new transaction can complete.
  • Transaction recording in the platform - every new matter gets its own transaction record even where the customer is repeated, so the audit trail stays clean.

When a fresh KYC is required for a repeat client:

  • The 2-year validity has lapsed (or is about to lapse before the next transaction completes).
  • The customer's risk rating has materially changed (e.g. new PEP hit, jurisdictional change).
  • Identity details have changed (legal name change, new ID document).
  • You form a suspicion that the identity may not be reliable any more.

See AUSTRAC's Overview of customer due diligence.

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