AML/CTF Risk Assessment Round Table: Initial, Ongoing and Enhanced CDD and Reporting

This facilitated round table will bring together banking and non-banking reporting entities to discuss the practical issues and solutions involved in conducting individual customer risk assessments across the customer lifecycle—from initial customer due diligence (CDD) ongoing CDD, and when enhanced CDD is required (including how these assessments connect to SMR and TTR reporting decisions).

Facilitated by GRC Solutions, the session is designed as a peer discussion forum. Participants will be encouraged to compare approaches, share what is working (and what is not), and explore how to evidence risk-based decisions in a way that aligns with AUSTRAC’s expectations around customer due diligence and reporting.

This session is suitable for AML/CTF reporting entities (including banking and non-banking organisations, and designated service providers such as legal, accounting, conveyancing, real estate and other designated services) who want to share practical experience and discuss how to approach individual customer risk assessments and due diligence in a defensible, consistent way.

What this round table will cover

In this 3-hour round table, we will explore:

• Individual customer risk assessment – in the real world: agreeing risk factors, defining “reasonable steps”, and documenting the rationale behind risk judgements (beyond a tick-box score).
• Initial CDD (onboarding): building a defensible customer profile, collecting and verifying information, and using risk assessment outputs to determine the level of due diligence required.
• Ongoing CDD: practical monitoring approaches, review triggers, and keeping customer risk ratings current as behaviour, products, geographies, or counterparties change.
• Enhanced CDD (ECDD): when escalation is appropriate, what information to seek (including source of funds / source of wealth where relevant), and how to evidence the “why” behind ECDD decisions.
• Connecting CDD/ECDD to reporting: how teams operationalise decision-making for Suspicious Matter Reports (SMRs) and Threshold Transaction Reports (TTRs), including common pain points and control gaps.
• Consistency, governance, and quality assurance: calibration across teams, record keeping, audit trail expectations, and how to prepare for regulatory engagement.

Key Learning Outcomes

By the conclusion of this round table, participants will be able to:

• Compare how peer organisations structure and document individual customer risk assessments across initial CDD, ongoing CDD and ECDD.
• Identify practical ways to evidence risk-based decisions (including escalation decisions) in line with AUSTRAC expectations.
• Pressure-test triggers for ongoing review and ECDD, and discuss how to improve consistency across teams.
• Explore how CDD outcomes connect to SMR and TTR reporting decisions, and common controls used to support timeliness and quality.
• Leave with a set of example questions, prompts, and “better practice” ideas to take back to your organisation.
• CPD points applicable

Event Details

Contact Us

For more information, please liaise with your Senior Relationship Manager or contact us.