Australian AML/CTF · Explainer

Identify a person without standard ID

When a person cannot provide standard identity documents, a careful alternative process may still complete initial CDD.

General information only, not legal, compliance, or other professional advice. Does not confirm compliance.

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Identify the reason for the missing evidence

Rules 6-10 provides a qualified identity measure for an individual who cannot obtain the necessary information or evidence. It also covers inaccessible evidence due to circumstances beyond the individual’s control.

The reporting entity must take reasonable steps to establish that the individual is who they claim to be. The measure does not permit staff to omit identity work.

Source: Federal Register of Legislation: Section 6-10(a) to (e).

Assess an alternative identity routeMissing information Available evidence Identity and risk Conclusion or escalation
  1. Missing information

    Record why the normal information is unavailable.

  2. Available evidence

    Consider reliable information reasonably available in the circumstances.

  3. Identity and risk

    Apply the relevant Rules 6-10 conditions and assess additional risk.

  4. Conclusion or escalation

    Explain what the evidence establishes and resolve remaining gaps.

Assess an alternative identity route

Missing standard ID is not permission to skip identity checks. No single alternative document combination works for every case.

Follow the process from top to bottom.

Apply all the conditions

If the individual is the customer, the business must identify customer risk from KYC information reasonably available before the service starts. KYC means know your customer.

It must collect risk-appropriate KYC information and take reasonable verification steps with reasonably available data. Its policies must address additional risk from the missing evidence.

The measure concerns identity. It does not automatically establish every other initial CDD matter or make the customer low risk.

Source: Federal Register of Legislation: Section 6-10(a) to (e).

Invented example: an emergency

A customer cannot access identity documents after an emergency. The business identifies the missing evidence and what suitable information remains available.

The business applies the conditions and its alternative process. It records the evidence and any additional risk.

This example does not prescribe a document combination or promise a successful result. Missing standard documents alone do not prove dishonesty.

Source: Federal Register of Legislation: Section 6-10(a) to (e).

Explain the decision

A practical note states the relevant circumstance, evidence, conclusion and limits. It distinguishes the alternative procedure from the normal procedure.

If the evidence cannot establish the necessary matters, staff refer the unresolved question through the business’s process. A valid reason for missing documents does not create evidence.

Source: Federal Register of Legislation: Section 6-10(a) to (e).

Sources and scope

Sources checked on 13 September 2026. This page is not continuously updated. Check the linked legislation and AUSTRAC guidance for current requirements.

How we prepare articles

This page does not cover: Universal alternative document list; Sector-specific identity requirements; Identity fraud investigation.

Common AML/CTF terms