A client can be familiar to the practice and still require a new service assessment. Years of tax work do not by themselves establish that the client previously received a designated service, that all relevant people have been identified, or that current information supports the new instruction. Start with the relationship and service history, then decide what existing evidence can legitimately support the next step.
Build a short relationship timeline
Record the services actually provided, when the relevant relationship began and what the new request changes. Distinguish ordinary tax or bookkeeping work from any earlier designated service. If a pre-commencement rule may apply, record the facts and current legal basis rather than using the date the contact was added to your software. The existing pre-commencement guide should be read with the current Act, Rules and the practice's own circumstances.
Separate reusable information from completed CDD
An old passport detail, company extract or trust deed may be useful evidence, but it is not an automatic approval of a different service. Assess whether it concerns the right person, remains accurate and supports the matters now required. Record what can be reused and why, what needs corroboration and which relevant parties have changed. Do not request a whole new document pack simply because a new job number was opened.
Work through a practical example
A practice has prepared accounts for an operating company for years and is now asked to help create a new trust with a corporate trustee. The new instruction involves different proposed roles and documents. Identify the relevant service and customer population before selecting checks. The history may help explain the commercial purpose, but it cannot fill missing facts about a new appointor, proposed trustee or person giving instructions for someone else.
Record the decision and work boundary
The handover should identify the applicable customer treatment, current risk, outstanding evidence and the person responsible for resolving it. Initial CDD ordinarily precedes the designated service; lawful delayed or transitional provisions have specific conditions and are not a general familiarity exception. Explain what work can proceed under the recorded conclusion. Reassess if the transaction, control structure or instructions change before the planned implementation is complete.
Official sources
Confirm the current rules against these primary sources, last checked .
Questions
Is every old tax client a pre-commencement customer?
No. That classification depends on the statutory and transitional conditions, including the designated-service relationship, not simply the age of the tax relationship.
Must all old evidence be collected again?
No. Assess reliability, currency, relevance and the applicable rules. Reuse should be reasoned, rather than automatic acceptance or automatic duplication.
Does a new instruction always remove transitional treatment?
Do not assume that. Assess the particular service, relationship change and applicable legal conditions, and escalate an uncertain conclusion.
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
- Existing customer transition6 min
A file-based approach to identifying pre-commencement customers, applying transitional CDD settings and maintaining ongoing due diligence after commencement.
- When an accounting engagement changes3 min
Keep a clear service decision when routine accounting work moves into company formation, transaction assistance or another potentially designated service.
- Ongoing CDD triggers6 min
An operational catalogue of customer events that should trigger AML/CTF risk, KYC, verification, enhanced due diligence and reporting review.