How customer risk assessment actually works—a guide for Tranche 2 entities
In our first risk assessment blog, we explained what risk assessment is and why it's mandatory from 1 July, 2026. Now let's get practical: How does customer risk assessment actually work?
Risk assessment isn't a single event—it's an integrated process that runs throughout your customer relationship.
The Big Picture: Two Phases of CDD
AUSTRAC structures Customer Due Diligence (CDD) into two distinct phases, each with its own risk assessment requirements:
1. Initial CDD: Before You Provide Services
Purpose: Understand who your customer is and what ML/TF risk they present before you begin providing designated services.
Key Requirements:
- Verify customer identity using approved methods
- Establish the nature and purpose of the relationship
- Determine the customer's ML/TF risk profile
- Decide what level of due diligence is appropriate
- Complete this before providing any designated service
Risk Assessment Role: Initial risk assessment determines whether you can proceed with standard CDD, or whether enhanced CDD is required.
2. Ongoing CDD: Throughout the Relationship
Purpose: Monitor the customer relationship for changes that could increase risk or trigger red flags.
Key Activities:
- Monitor for unusual transactions or behaviour
- Review and update customer information at appropriate frequencies
- Reassess risk if circumstances change significantly
- Identify triggers for enhanced due diligence
- Submit suspicious matter reports when necessary
Risk Assessment Role: Periodic reassessments ensure your understanding of the customer's risk remains current.
Common Questions
a) "How long does the whole CDD process take?"
For low-risk customers (70-80% of cases):
- Identity verification: 5-15 minutes (Customer time)
- Automated processing: Seconds to minutes
- Risk assessment: Automatic upon verification
- Mitigation review: Minutes (usually none required)
- Total elapsed time: Same day, often within an hour
For medium-risk customers:
- Identity verification: Same as above
- Risk assessment: Automatic
- Mitigation completion: Hours to days (depends on info gathering)
- Total elapsed time: 1-3 business days
For high-risk or complex customers:
- Identity verification: Same as above
- Enhanced due diligence: Days to weeks
- Senior management approval: Additional time
- Total elapsed time: 1-2 weeks or more
b) "Do I need to reassess existing customers?"
Pre-commencement customers (customers before July 1, 2026):
Good news: You don't need to conduct initial CDD again unless:
- You need to file a suspicious matter report about them
- There's a significant change resulting in medium/high ML/TF risk
- They request new designated services materially different from existing relationship
However, you must:
- Monitor for unusual transactions and behaviours
- Review and update KYC information at appropriate frequency
- Maintain ongoing CDD throughout relationship
Practical approach:
- Risk-based prioritization of existing customer remediation
- Phased approach over 18-month window
- Focus first on high-risk or high-value customers
c) "What if I get the risk assessment wrong?"
The good news:
- Customer risk assessment is based on objective criteria from your rules
- System applies rules consistently
- Documentation shows your reasoning
If challenged:
- AUSTRAC expects reasonable grounds, not perfection
- Your documented process demonstrates good faith
- Can revise and improve rules over time
- Regular reviews show ongoing commitment
Protection through documentation:
- Detailed mitigation comments
- Clear rationale for decisions
- Evidence of rule application
- Proof of ongoing monitoring
Key Takeaways
- Risk assessment is integrated into customer onboarding—not a separate, disconnected process
- Most of the process is automated when using modern compliance platforms like VerifiMe
- Initial CDD happens before you provide designated services—it's a prerequisite, not an afterthought
- Ongoing CDD continues throughout the relationship—this isn't "set and forget"
- Mitigations are your compliance toolkit—they demonstrate how you manage identified risks
- Documentation happens automatically when using proper systems—your audit trail builds itself
- Most customers are low risk and experience minimal friction
- The process gets easier as you gain experience and refine your rules