Your AML/CTF program covers your clients.
Does it cover your people?
Since 1 July 2026, 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, and putting it into practice takes more than running a few checks when someone joins your business.
Training and checks aren’t enough
Training, reference checks and police checks satisfy other obligations. On their own, they don't satisfy this one.
Not a one-off
Personnel Due Diligence isn’t just a single check completed once. It’s an ongoing obligation, not just a point in time exercise.
No grace period
For people already in AML/CTF roles at your firm, the obligation was live from 1 July 2026.
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 the work Clearhouse does. We turn that requirement into a process you and your people can actually follow, and your business can manage over time.
It doesn't stop at hiring.
Personnel Due Diligence isn't simply a pre-employment check.
Your process also needs to account for what happens after someone joins, as roles change, responsibilities shift, and circumstances evolve. The practical challenge is building that into the way your business actually operates, not just your policy document.
The challenge isn't identifying that Personnel Due Diligence is required. It's translating the requirement into something that works in practice.
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 published guidance distinguishes higher-risk roles from other AML/CTF-related roles, and expects more comprehensive due diligence for those positions. Firms that map their roles, identify which carry greater risk, and apply due diligence proportionate to that risk tend to catch what a generic, one-size-fits-all process misses.
The question isn't simply "did we run a check?"
It's "have we thought about what due diligence is appropriate for this role, and why?"
Recent AUSTRAC activity across professional services has also highlighted the importance of understanding the risks associated with the people and functions involved in regulated businesses.
The question isn't whether Personnel Due Diligence appears in your AML/CTF program. It's what happens because it's there.
Experience that comes from doing the work
I'm Elizabeth Neely. Before founding Clearhouse, I spent almost 12 years at one of Australia's Big 4 banks, including seven years building and leading its Personnel Due Diligence capability.
Clearhouse brings that experience, across people, risk, governance and operations, to professional services and real estate businesses working through the same requirement for the first time.
Who Clearhouse is for.
Clearhouse works with businesses navigating the practical side of Australia's AML/CTF reforms, including accounting firms, law practices, real estate businesses, corporate advisory firms and conveyancers.
The common thread isn't size or structure. It's the need to turn a regulatory requirement into something that works across the people, processes and systems already in the business.
Still working out what this means in practice?
Not sure where to start?
Book a complimentary 15-minute conversation with Clearhouse. It’s a chance to briefly explain where you’re at, ask questions and work out whether Clearhouse can help.
It isn’t a detailed assessment or gap analysis. If a closer look would be useful, we’ll walk you through how the Personnel Due Diligence Health Check works.