---
title: What are some common Customer Due Diligence (CDD) mistakes?
description: "What are some common Customer Due Diligence (CDD) mistakes - Mistake 1: Not Verifying Beneficial Owners \"I verified the company director, that's enough\" Problem."
---

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# What are some common Customer Due Diligence (CDD) mistakes?

## Mistake 1: Not Verifying Beneficial Owners "I verified the company director, that's enough" Problem.

**Mistake 1: Not Verifying Beneficial Owners**

"I verified the company director, that's enough"

**Problem:** The director might be a nominee for someone else. You must identify anyone with 25%+ ownership or control.

**Fix:** Always ask "Who owns or controls this entity?" and verify those individuals. easyAML queries business registers to ensure you're getting the most accurate view of directors and beneficial owners.

**Mistake 2: Accepting Poor Quality Documents**

"The photo is blurry but I can kind of see them"

**Problem:** You're responsible for adequate verification. Poor quality = inadequate verification.

**Fix:** Insist on clear, legible documents. easyAML ensures the clients submit legible documents and verifies them for you!

**Mistake 3: Verifying Too Early**

"I verified them when they first inquired, 6 months ago"

**Problem:** Verification must be done before providing the service. Old verification might be outdated.

**Fix:** Verify immediately before or at the time of providing services. If time has passed, refresh your checks.

**Mistake 4: Not Understanding Transaction Purpose**

"They're buying property, that's all I need to know"

**Problem:** You need to understand WHY they're buying, with whose money, for what purpose.

**Fix:** Ask questions. Understand the full context. Document their answers.

**Mistake 5: Same CDD for Everyone**

"I use the same checklist for all clients"

**Problem:** High-risk clients need enhanced checks. One-size-fits-all is inadequate.

**Fix:** Risk-assess each client and tailor your CDD to their risk level. easyAML automatically classes a clients risk based on a number of factors.

**Mistake 6: Not Documenting the Process**

"I definitely checked their ID, I just didn't write it down"

**Problem:** If you can't prove you did CDD, AUSTRAC treats it as if you didn't.

**Fix:** Document everything. Keep records for 7 years.

**Mistake 7: Trusting Client's Word**

"They seem honest, I don't need to verify"

**Problem:** Criminals often seem trustworthy and professional. That's how they succeed.

**Fix:** ALWAYS verify. Trust but verify. Your gut feeling isn't CDD.

**Mistake 8: Ignoring Red Flags**

"Something seemed off but I didn't want to be rude by asking more questions"

**Problem:** Red flags require investigation. Ignoring them can lead to facilitating money laundering.

**Fix:** If something doesn't add up, ask more questions. It's your job, not rudeness.

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