Is a manual KYC permitted for customers unable to use the digital flow?
Yes, AUSTRAC's framework is technology-neutral; manual document sighting (in person, with you holding the original) is acceptable provided all CDD components are still completed.
Yes. AUSTRAC's CDD framework is technology-neutral - it requires identity to be established on reasonable grounds using reliable and independent sources, but it doesn't mandate that the process be digital. Manual document sighting (in-person, with you holding the original) remains acceptable.
What you still must do, even on a manual VOI:
- Collect and verify the identity information against reliable and independent sources (the documents themselves count, when sighted in person).
- Run PEP, sanctions and adverse-media screening electronically - this part can't be done on paper.
- Make and keep a record of the verification (the AUSTRAC retention period is 7 years).
In easyAML: create the transaction, choose the manual VOI path, upload a scan of the sighted documents, and the platform runs PEP/sanctions/adverse-media automatically and stores the file alongside the transaction. The audit trail is identical to a digital VOI.
Background reading: AUSTRAC, Overview of initial customer due diligence.