What does AUSTRAC's Personnel Due Diligence (PDD) requirement cover for non-CO staff?
An integrity assessment scaled to ML/TF risk: identity verification (all), police checks (high-risk roles), bankruptcy checks and a role-appropriate questionnaire.
Per AUSTRAC Rules 5–14, PDD for non-CO staff is an integrity assessment scaled to the role's ML/TF risk. The components:
- Check: Identity verification
High-risk roles (CO, senior CDD): ✓ Always required
Lower-risk roles (Frontline, support): ✓ Always required - Check: Police check
High-risk roles (CO, senior CDD): ✓ Generally required
Lower-risk roles (Frontline, support): Optional; based on firm's risk - Check: Bankruptcy check
High-risk roles (CO, senior CDD): ✓ Recommended
Lower-risk roles (Frontline, support): Optional - Check: Sanctions / adverse media screening
High-risk roles (CO, senior CDD): ✓ Required
Lower-risk roles (Frontline, support): ✓ Required - Check: Reference checks
High-risk roles (CO, senior CDD): ✓ Recommended
Lower-risk roles (Frontline, support): Recommended - Check: Qualification confirmation
High-risk roles (CO, senior CDD): ✓ Recommended
Lower-risk roles (Frontline, support): Based on role - Check: Regulatory breach history
High-risk roles (CO, senior CDD): ✓ Recommended
Lower-risk roles (Frontline, support): Based on role - Check: Self-disclosures
High-risk roles (CO, senior CDD): ✓ Required
Lower-risk roles (Frontline, support): ✓ Required
The "less prescriptive" treatment for other staff reflects AUSTRAC's risk-based approach - the depth of integrity testing should match the staff member's actual exposure to AML risk. A Frontline Staff member who initiates KYC requests but doesn't sign off transactions has a narrower exposure than a senior CDD User or a CO.
Firms with formal HR-side onboarding processes may already cover several of these items - the PDD module in easyAML captures and structures the information for AUSTRAC purposes rather than duplicating existing employer processes. The CO can mark items as "covered externally" with supporting evidence uploaded.