Importing a practice's client register is an administrative task, not a legal classification exercise. An imported contact might receive only routine tax services, might be the representative of another customer or might need further CDD for a designated service. Plan the migration so those differences remain visible. The aim is to preserve reliable information and assign review work without giving every imported row an unjustified approved status.
Agree the mapping before transferring the register
Identify the source of legal names, entity identifiers, contact details and relationship links. Keep individuals separate from companies and trusts, and distinguish a trading name from the legal customer. Use a sample that includes a company, corporate trustee, shared email and archived contact. Check the proposed mapping with the person who knows the source system. An empty field should remain an identified gap rather than being populated with a guessed value.
Preserve provenance and resolve duplicates
Keep a protected migration record with the source, extraction date, mapping version, authorised operator and reconciliation results. Match records using appropriate identifiers and context; email alone can join unrelated entities. Review suspected duplicates before merging histories. Account for accepted, rejected and unresolved rows, including partial failures. A successful upload response does not establish that every intended record arrived or that evidence links still point to the correct customer.
Triage service and customer-treatment questions
Prioritise records with imminent relevant work, unresolved identity or authority, material risk changes and incomplete evidence. Assess service scope and any pre-commencement treatment from the actual facts. Do not automatically classify every long-standing accounting contact as exempt or every new software record as a newly acquired legal customer. Link existing service and CDD history where usable, and assign the additional inquiry rather than silently resetting or approving it.
Reconcile the result and control source copies
Compare totals and a risk-based sample of fields and relationships after import. Keep a list of unresolved cases and owners, including records deliberately excluded because no designated service is provided. Restrict temporary spreadsheets and dispose of unnecessary copies under the applicable retention and privacy requirements. Preserve required historical evidence. Do not delete the authoritative source merely because a new system displays a similar client count.
Official sources
Confirm the current rules against these primary sources, last checked .
Questions
Does importing a client mean their CDD is complete?
No. Imported information must be assessed for its relevance, reliability and the applicable service and customer-treatment requirements.
Can shared email addresses identify duplicates?
They are a useful review signal, but family groups and related entities often share an address. Confirm the legal person before combining records.
Should every migrated client be reverified at once?
Apply the relevant legal conditions and risk-based priorities. Avoid both blanket approval and unnecessary blanket recollection without assessing the existing evidence.
General information for Australian professionals, not legal advice. It does not replace the AML/CTF Act, the Rules or AUSTRAC guidance. See our editorial standards.
Keep reading
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