How does the Delayed Initial Due Diligence (DCDD) exception work?
DCDD allows a reporting entity to start a designated service for a real estate transaction before fully completing.
Under the DCDD exception, a reporting entity can commence a designated service for a real estate transaction without having fully completed the initial CDD on all parties - provided certain conditions are met.
What you still have to do during the delay window
Even when delaying, AUSTRAC expects: a documented determination (made before starting) that the gateway conditions are met; the same KYC information you would ordinarily collect - collection itself isn't delayed, you just don't have to verify everything yet; an ML/TF risk assessment based on the information collected; PEP and sanctions screening, which can't be skipped just because verification is delayed; and verification completed within the prescribed window, with care around receiving funds during the window.
Related articles
- How does delayed diligence apply to conveyancers, lawyers, and settlement agents (Rules s 6-15)?
- How do all sales agents at a real estate agency get covered - does each agent need access?
- What are NOT valid reasons to allow Delayed Customer Due Diligence?
- What conditions must be met before delayed Customer Due Diligence?
- What you still have to do during the delay due diligence window?