What do we need to do about our existing clients on 1 July 2026?

Most firms focus entirely on new clients when preparing for AML/CTF compliance. The harder problem is the one already on your books. Every active matter on the day your obligations commence may require CDD, and many of your existing clients have never been asked to provide identity documents in this context.

What this means practically:

• Audit your current active matters and identify which require CDD. This is a manual exercise unless your PMS can filter by matter status, client type, and transaction type. For most firms, it takes longer than expected.
• Prioritise existing clients by risk level for retrospective CDD. You may not be able to verify every existing client before the deadline. A risk-based approach requires a documented methodology for prioritisation.
• Communicate AML requirements to existing clients with a clear, consistent explanation. A long-standing client who receives an unexpected request for identity documents will often push back. Your team needs a script, and the communication needs to go out early enough that you can follow up before the deadline.
• Decide what to do with clients who cannot or will not provide CDD. This is a real scenario. You need a documented process for declining to continue acting, and your team needs to know what to say. The process should be agreed before it's needed.

For a firm with 200+ active matters, the existing-client exercise is a multi-week undertaking. Start it early.

Full detail in our Operational Readiness Checklist, Part 1, Section 5.

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