Your AML/CTF program covers your clients.
Does it cover your people?
Since 1 July 2026, tens of thousands of Australian businesses have been regulated for the first time under Australia's AML/CTF regime. Most of the attention has gone to customer due diligence, reporting and training. Personnel Due Diligence is a different obligation. It covers the people doing the work, and it takes more than a few checks when someone joins.
Training isn’t enough
Training is a separate part of your program. Doing one doesn’t cover the other.
Not a one-off
Personnel Due Diligence isn’t a single check completed once. AUSTRAC’s guidance applies it before someone starts and on an ongoing basis, including periodic reassessment.
No grace period
From 1 July 2026 AUSTRAC expects due diligence on people already performing AML/CTF functions, not only new starters.
Easy to overlook
Personnel Due Diligence is new territory for newly regulated businesses. It's easy to assume training has covered more ground than it actually has.
You may already have it covered in your documentation.
The question is what happens next: who’s responsible for identifying the roles that need it, applying the right level of scrutiny, and keeping the process running as people and circumstances change.
Personnel Due Diligence is more than a line in your AML/CTF program.
Roles
Which roles need to be subject to due diligence, and which of those carry greater risk?
People
What happens when someone joins, moves into a different role, or their circumstances change?
Records
Can you demonstrate what was done, what was found and why decisions were made?
Decisions
What happens when a check or disclosure raises something that needs consideration?
On paper isn’t the same as operationalised.
A policy sets the standard. It doesn't run itself.
This is where Clearhouse comes in. We take your policy and build the framework that turns it into a process your people can follow and your business can keep running.
It doesn't stop at hiring.
AUSTRAC’s guidance applies Personnel Due Diligence before someone starts, on an ongoing basis, and to people already performing AML/CTF functions.
That includes periodic reassessment to confirm someone stays suitable for the role.
Roles change. Responsibilities shift. Circumstances move on. A policy document can’t track that by itself, and that’s the part Clearhouse works on.
The requirement is risk-based.
Your approach should be too.
A single screening process applied to everyone may feel simple. It doesn't necessarily reflect the different responsibilities and risks across your business.
AUSTRAC’s guidance expects you to identify high-risk roles, so the level of due diligence matches the role and the money laundering and terrorism financing risks that come with it. In practice that means mapping your roles, working out which carry more risk, and tailoring the due diligence to fit, rather than running one process for everyone.
The useful question is what due diligence is appropriate for this role, and why.
Experience that comes from doing the work
I’m Elizabeth Neely. Before founding Clearhouse, I spent almost 12 years inside one of Australia’s Big Four banks, including seven years building and leading its employee due diligence capability.
I bring that experience to accounting firms, law practices, real estate businesses, conveyancers and corporate advisory firms working through the same requirement for the first time.
Who Clearhouse is for.
Clearhouse works with accounting firms, law practices, real estate businesses, conveyancers and corporate advisory firms who have an AML/CTF program in place and need the people side of it to work.
Size and structure vary. The job doesn’t: turn what’s written down into something your people follow.
Still working out what this means in practice?
Read: What Personnel Due Diligence actually requires under Tranche 2
Not sure where to start?
Book a complimentary 15-minute conversation with Clearhouse.
It’s a chance to talk through where you’re at, ask questions and work out whether Clearhouse can help. If a closer look would be useful, we’ll walk you through how the Personnel Due Diligence Health Check works.