CDD by country: Australia, New Zealand, UK and South Africa

Markdown

View as Markdown

Customer Due Diligence (CDD) works the same way in OnboardMe in every country. Some parts are set up for where your business is based: the checklists, review periods, business lookups and company register guidance. This article explains what's different in each country and points you to your regulator's guidance.

Important: This article is a quick guide to how OnboardMe fits each country's rules. It isn't legal advice. Your AML program, and your regulator's or supervisor's guidance, decide what you must do.

Why it matters

  • The right checklist for your country. You'll only see standard checklists for your country, with guidance that names your local company register.

  • Review periods match your financial year. Cases are grouped by the financial year used in your country.

  • Know where the wording differs. Some on-screen wording uses Australian terms. This article explains what they mean for you.

At a glance

Australia

New Zealand

United Kingdom

South Africa

Main law

AML/CTF Act 2006

AML/CFT Act 2009

Money Laundering Regulations 2017

Financial Intelligence Centre Act 2001 (FIC Act)

Regulator or supervisor

AUSTRAC

Department of Internal Affairs (DIA)

HMRC or your professional body (such as ICAEW, ACCA or AAT)

Financial Intelligence Centre (FIC)

What OnboardMe calls a designated service

Designated service

Captured activity

Regulated (in scope) service

Activity of an accountable institution

Your program is called

AML/CTF program

AML/CFT programme

Policies, controls and procedures

Risk Management and Compliance Programme (RMCP)

Compliance officer

AML/CTF compliance officer

AML/CFT compliance officer

Money Laundering Reporting Officer (MLRO)

Compliance officer

Review period in OnboardMe

July to June

April to March

April to March

March to February

Business lookup on D1

ABR lookup (ABN, ACN)

NZBN, Registration Number

VAT Number, Company Number

VAT Number, Registration Number

Company register evidence

ASIC

Companies Office

Companies House

CIPC

Wording that's the same in every country

A few labels on the case screen use Australian terms in every country:

On screen

What it means for you

Designated service

Any service your AML rules apply to

AML/CTF approval

Approval of the case by your nominated approver

AML/CTF compliance officer

Your AML compliance officer or MLRO

20-day verification window (section B)

The Australian timeframe for delayed verification. See Delayed verification below

Questions and help text in the checklist can be reworded to suit your country. See Customising CDD checklists.

Australia

  • Regulator: AUSTRAC. From 1 July 2026, accountants, lawyers, conveyancers and real estate agents who provide designated services are regulated (tranche 2). You must enrol with AUSTRAC within 28 days of first providing a designated service.

  • Designated services for accountants include setting up companies and trusts, acting as or arranging a nominee, handling client money, and helping clients buy or sell businesses or real estate.

  • When: initial CDD must be completed before you start providing the designated service.

  • In OnboardMe: the Australian Business Register lookup checks an ABN against the client name. Use ASIC extracts as the main evidence for companies. Standard checklists are named "CDD/KYC - [client type] - Australia".

  • Guidance: AUSTRAC's accountant program starter kit and its customer due diligence guides.

New Zealand

  • Regulator: the Department of Internal Affairs (DIA), which is the AML/CFT supervisor for accountants.

  • Captured activities for accountants include forming legal persons or arrangements, acting as or arranging a nominee director, shareholder or trustee, and managing client funds or property.

  • Forming companies and trusts: under regulation 5F of the AML/CFT (Definitions) Regulations, the customer is the person who instructs you. You must also take reasonable steps, based on risk, to verify anyone who will be a beneficial owner of the new entity. See Who to run CDD on.

  • In OnboardMe: D1 shows Business identifiers for the NZBN and Registration Number. Use Companies Office extracts as evidence. Standard checklists are named for New Zealand.

  • Guidance: the DIA's guidance for accountants, and the joint supervisors' guidelines on CDD for companies, trusts and beneficial ownership.

United Kingdom

  • Supervisor: your professional body if you're a member of one (such as ICAEW, ACCA, AAT, CIOT or ATT), otherwise HMRC.

  • In scope: accountancy and tax services, and trust or company services such as forming companies. A company formation counts as a business relationship, even if it's the only work you do for the client.

  • CDD levels: simplified, standard or enhanced, depending on risk. Medium and high risk cases in OnboardMe follow the enhanced steps (delayed CDD, source of funds and wealth, and approval).

  • In OnboardMe: D1 shows Business identifiers for the VAT Number and Company Number. Use Companies House extracts as evidence, and check the register of people with significant control (PSC). Standard checklists are named for the UK.

  • Guidance: the CCAB anti-money laundering guidance for the accountancy sector, and HMRC's guidance for trust or company service providers if HMRC supervises you.

South Africa

  • Regulator: the Financial Intelligence Centre (FIC). Since 19 December 2022, trust and company service providers, including accountants who provide those services, are accountable institutions under item 2 of Schedule 1 to the FIC Act. They must register with the FIC.

  • What you need: a Risk Management and Compliance Programme (RMCP), customer due diligence, record keeping, staff training and reporting to the FIC.

  • In OnboardMe: D1 shows Business identifiers for the VAT Number and Registration Number. Use CIPC records as evidence for companies, and the trust deed and Master's letters of authority for trusts. Standard checklists are named for South Africa.

  • Guidance: the FIC's guidance notes and public compliance communications for accountable institutions, and your professional body (such as SAICA or SAIPA).

Delayed verification

Section B. Delayed CDD appears for medium and high risk clients. Its wording, including the 20-day window, reflects the Australian rules.

Country

Delaying verification

Australia

Allowed in limited circumstances set out in the AML/CTF Rules. Finish verification as soon as practicable, within the timeframe the Rules set

New Zealand

Allowed in limited cases, where it's essential not to interrupt normal business and the risk is managed. Finish as soon as practicable

United Kingdom

Allowed during the setting up of a business relationship if it's needed to avoid interrupting normal business and the risk is low. Finish as soon as practicable

South Africa

CDD is generally required before you establish the business relationship. Follow your RMCP

If you use section B outside Australia, record the rule and timeframe that apply to you in the completion plan. Sanctions screening can't be delayed in any country.

Next steps

Was this article helpful?

Still need help?

Contact us