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What are NOT valid reasons to allow Delayed Customer Due Diligence?

AUSTRAC rules out customer hurry, immature internal systems, untrained staff, cost concerns, vendor reluctance to provide ID, or unsettled agency policies as reasons to delay initial CDD.

Useful for prospect education — AUSTRAC's stated position rules out:

  • Customer is in a hurry / wants to move fast
  • Internal systems are slow or not yet built
  • Staff haven't been trained on CDD yet
  • Cost or commercial efficiency concerns
  • The vendor doesn't want to be asked for ID
  • The agency hasn't decided how to handle CDD

The "interruption to ordinary course of business" test is about the transaction's operational reality (e.g., the auction structure, the exchange-to-settlement timing), not the agency's readiness.


AUSTRAC source links — delayed initial CDD

Primary:

Supporting:

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