What you still have to do during the delay due diligence window?
Even when delaying due diligence, a written determination, KYC information collection, an ML/TF risk assessment, and PEP and Sanctions screening must all still occur.
Even when delaying, AUSTRAC expects:
- A documented determination (made before starting) that the two gateway conditions are met
- The same KYC information you would ordinarily collect — collection itself isn't delayed, you just don't have to verify everything yet under the general provisions
- An ML/TF risk assessment based on the information you have collected
- PEP and Sanctions screening — these checks can't be skipped just because verification is delayed
- Verification completed within the prescribed window
- If you receive funds during the window, avoid disbursing them in a way that defeats the purpose of CDD (AUSTRAC suggests returning electronic funds to the originating account if you can't complete CDD)
Related articles
- How does delayed diligence apply to conveyancers, lawyers, and settlement agents (Rules s 6-15)?
- Glossary: Key Terms & Definitions
- What are NOT valid reasons to allow Delayed Customer Due Diligence?
- What conditions must be met before delayed Customer Due Diligence?
- How does the Delayed Initial Due Diligence (DCDD) exception work?