Australian AML/CTF · Explainer

Ongoing CDD and transaction monitoring

Ongoing customer due diligence connects customer information, observed activity and changes in risk.

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

Start with: Initial customer due diligence

What ongoing CDD covers

Ongoing customer due diligence (CDD) includes monitoring transactions and behaviour. It also includes customer risk and information reviews in a business relationship.

The initial customer record gives a starting point. Later activity can require a different response. An identity check alone cannot perform that work.

Section 30 applies to designated services at or through an Australian permanent establishment, subject to the applicable exceptions. Read the service conditions and transition rules.

Sources: AUSTRAC: Ongoing CDD topic index; Federal Register of Legislation: Section 30; Part 2 exceptions and transitional provisions.

From expected activity to a recorded decisionExpected activity Observed change Review Decision
  1. Expected activity

    Describe what the available customer information supports.

  2. Observed change

    Identify the specific difference.

  3. Review

    Examine the explanation and evidence.

  4. Decision

    Record the result and any next action.

From expected activity to a recorded decision

Invented example. Illustrative workflow. Read the page and current primary guidance for conditions and exceptions.

Follow the process from top to bottom.

Three parts of ongoing CDD

Ongoing CDD connects monitoring with customer risk and information. For a business relationship, risk and KYC information need review in the specified circumstances.

Updates or further verification depend on the applicable conditions. The work must reflect relevant risks and changes. A new controller can matter without a change in payment amounts.

Sources: AUSTRAC: Ongoing CDD obligations overview; AML/CTF policies and ongoing CDD; Federal Register of Legislation: Section 30; Part 2 exceptions and transitional provisions.

Write down what ordinary activity looks like

Monitoring needs a useful starting description. In a suggested customer record, state the purpose of the service, expected parties, payment arrangements and any other relevant activity. Use information the business can reasonably obtain. A record saying business customer provides little help when staff later decide whether new instructions fit the relationship.

AUSTRAC requires monitoring of transactions and behaviour, including for customers using services occasionally. Review and update duties for risk and KYC information apply to business relationships. Keep that distinction visible in the procedure. A change of controller or unexplained representative can matter even when the transaction value has not changed.

Sources: AUSTRAC: Ongoing CDD obligations overview; AML/CTF policies and ongoing CDD; What you must monitor for; Responding to unusual transactions and behaviour; Review and update information and customer ML/TF risk; Examine your ongoing CDD; Record keeping; Federal Register of Legislation: Section 30; Part 2 exceptions and transitional provisions.

Invented example: assess a change in trading activity

A fictional customer normally receives payments from Australian retailers. The next matter includes payments from an overseas distributor. A staff member notes the difference and examines the stated purpose of the work. The customer says it has signed a distribution agreement. The reviewer compares that explanation with the agreement, parties and payment references that are available.

If the evidence supports a new trading arrangement, the record can describe why the expected activity changes. If the names or terms conflict, the remaining gap needs a further decision. Merely rewriting the expected profile to match the payments would remove the alert without describing it.

The reviewer makes separate decisions about the alert, customer information, customer risk and any reporting obligation. A supported commercial explanation may resolve one question while another remains open. The workflow records who owns each follow-up so an unresolved matter is not lost when the first alert is closed.

Sources: AUSTRAC: Ongoing CDD topic index; AUSTRAC: Ongoing CDD obligations overview; AML/CTF policies and ongoing CDD; What you must monitor for; Responding to unusual transactions and behaviour; Review and update information and customer ML/TF risk; Examine your ongoing CDD; Record keeping; Federal Register of Legislation: Section 30; Part 2 exceptions and transitional provisions.

A changed customer needs a connected reviewNew activity Customer information Response
  1. New activity

    A fictional customer starts activity that differs from the existing file.

  2. Customer information

    Examine whether the customer’s circumstances or explanation have changed.

  3. Response

    Assess the risk and applicable actions. Keep the reason for the decision.

A changed customer needs a connected review

Invented example. Read this visual with the source conditions and explanation in this section.

Follow the process from top to bottom.

One change can require four separate decisionsAlert outcome Customer information Customer risk Reporting decision
  • Alert outcome

    Explain whether the unusual activity is resolved.

  • Customer information

    Decide whether relevant KYC information needs review or update.

  • Customer risk

    Record whether the change affects the risk assessment.

  • Reporting decision

    Assess the reporting test separately. Closing an alert does not settle it.

One change can require four separate decisions

Invented example. Illustrative review for a business relationship. These decisions can overlap. This is not a fixed order.

Separate evidence questions. An answer to one does not settle the others.

Separate the decisions

In this invented example, closing an alert and deciding whether to submit a suspicious matter report are different decisions. The record should make that distinction visible. It should show what was reviewed, who reviewed it and what remains uncertain. If the business changes its expected customer profile, it should describe why the new profile is supported. Merely increasing an expected transaction amount to stop future alerts would hide the original question.

A reviewer also needs a way to return to unresolved information.

Source: AUSTRAC: Ongoing CDD topic index.

Examine whether the process works

An illustrative quality check selects a small set of closed and open reviews. Ask whether another trained person can understand each decision without speaking to its author. Look for missing evidence, unexplained delays and repeat alerts that were assessed in isolation. Use those findings to improve instructions and escalation paths. This is a proposed operating check, not a claim that a particular sample size satisfies the law.

Consult the detailed AUSTRAC monitoring guidance before setting the business process or changing its controls.

Source: AUSTRAC: Ongoing CDD topic index.

Test manual and automated monitoring the same way

A small business can ask whether its process detects relevant changes, directs them to a responsible person and records the outcome. For a manual process, examine how staff identify cases that need review. For software, examine which data and behaviours it can actually observe. Neither a spreadsheet nor an alert engine can review information that never enters the process.

A suggested quality check follows one case from the original change through the evidence, decision and follow-up. Examine that staff can distinguish alert arrival from suspicion formation. Review repeated low-value events together where relevant, rather than assuming each isolated event describes the pattern. This is an operating example. It does not prescribe a legal review frequency or sample size.

Sources: AUSTRAC: Ongoing CDD obligations overview; AML/CTF policies and ongoing CDD; What you must monitor for; Responding to unusual transactions and behaviour; Review and update information and customer ML/TF risk; Examine your ongoing CDD; Record keeping; Federal Register of Legislation: Section 30; Part 2 exceptions and transitional provisions.

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: A complete monitoring procedure for your business; Every ongoing CDD exception.

Common AML/CTF terms