Contents
What the tool does
The Group CDD Interim Tool captures Customer Due Diligence (CDD) information using a group-based model: one file per related client group (a family group with multiple entities, for example) rather than one record per entity. Accounting firms typically work this way, and the tool is structured to match.
Key capabilities:
- Group scoping interview to identify entities, controllers, and risk factors
- Per-entity CDD capture (company, trust, SMSF, partnership, sole trader)
- Shared Related Parties register: enter a person's details once, link them to multiple entities
- Designated service, source of funds, source of wealth, and ongoing CDD trigger fields (separate fields per entity)
- Customer acceptance decision record
- Entity relationship diagram
- Save to Excel / Load from Excel for data persistence
- Print / Save as PDF to file against your AML/CTF program
How to access it
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Log in to Firm Verify and select your firm. |
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Navigate to Clients in the main navigation. |
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The Group CDD Interim Tool is embedded on the Clients screen as an interactive Excel-style tool. |
Recommended CDD workflow
Until the full Firm Verify CDD module is available, use this four-step process for each new client group:
| Step | Action | Where |
|---|---|---|
| 1 | Build your AML/CTF Program (Risk Assessment, Policy, Process) | Firm Verify › Firm › Program |
| 2 | Verify individual identity via BGLiD (connected through CAS360) | CAS360 |
| 3 | Capture CDD and risk rating in this tool, then Print/Save as PDF and file it against your program | Firm Verify › Clients |
| 4 | Import your interim records into Firm Verify when the full CDD module releases | Firm Verify (coming) |
Tool sections
The tool is organised into tabs. Work through them in order for each new group.
Group Details
Start here for each new client group. Enter:
| Field | Required | Description |
|---|---|---|
| Group / family name | Required | Name used to identify this group across all saved files (e.g. "Smith Family Group") |
| Prepared by | Optional | Name of the staff member completing this CDD record |
| Date started | Optional | Date the engagement began. Used to auto-calculate next review due dates for each entity. |
| Relationship description | Optional | Free-text description of how the entities in this group are connected |
Scoping Interview
A set of yes/no questions to identify the full scope of the group. Each question surfaces entities or risk factors you may need to capture: whether there are foreign nationals, offshore assets, related trusts, and so on. Answering "yes" prompts you to add the relevant entity or note the risk factor.
Related Parties Register
A shared register of all individuals connected to entities in the group: directors, beneficial owners, trustees, appointors, and other key position holders. Enter each person once and link them to as many entities as needed. Fields include:
- Full legal name, date of birth, residential address, country of residence
- Nationality, tax residency, occupation
- PEP status, sanctions screening, adverse media check
- Identity verification method and date
Use the Copy from control on any person card to copy a residential address and country of residence from another register person. Useful when multiple family members share an address.
Entities
Add a tab for each entity in the group. Supported entity types:
- Company (default)
- Trust
- SMSF
- Partnership
- Sole trader — use only when the individual is themselves the client being onboarded under an ABN. Do not duplicate people from the Related Parties register as Sole trader entities.
For each entity, capture:
| Section | What to enter |
|---|---|
| Entity details | Legal name, ACN/ABN, registration date, jurisdiction, registered address |
| Designated service | Select from: company secretarial, tax agent, accounting/bookkeeping, SMSF admin, financial planning, insolvency, real property, trust/company admin, or other |
| Source of funds | Where the funds used in this engagement come from (e.g. business revenue, savings, loan proceeds) |
| Source of wealth | The broader origin of the entity's wealth (e.g. business operations, inheritance, investment returns) |
| Key position holders | Link people from the Related Parties register as directors, beneficial owners, trustees, members, appointors, or representatives |
| Risk assessment | Rate each risk factor. The tool calculates a preliminary risk indication based on your firm's configured methodology. Review and override as needed. |
| Monitoring frequency | Suggested review intervals based on risk rating: High = every 12 months, Medium = every 24 months, Low = every 36 months. Set per your firm's AML/CTF program. |
| Next review due | Auto-calculated from the Group start date and the entity's risk rating. Override manually if needed. Manual dates are not cleared when the risk rating changes. |
| Ongoing CDD triggers | Tick any triggers that apply: ownership change, director change, appointor change, trustee change, new service, unusual transaction, sanctions hit, PEP change |
Customer Acceptance Decision
Record the firm's final acceptance decision before sign-off. Options: Accepted, Accepted with conditions, Declined, or Exit relationship. Capture the reason, approving partner or manager, and date. This section exports to its own sheet in the Excel file and prints on the PDF.
Sign-Off
Space to record reviewer and approver sign-off before filing the PDF. Your firm's AML/CTF program should define the sign-off process for CDD records.
Saving and loading data
| Action | What it does |
|---|---|
| Save to Excel | Downloads all entered data as an .xlsx file. Save after every session and keep it in your client file. All fields are included: designated service, source of funds, source of wealth, ongoing CDD triggers, and acceptance decision. |
| Load from Excel | Restores a previously saved .xlsx file into the tool. All fields restore without data loss. Use this to resume work on an existing group. |
| Reset | Clears all data in the current session. Use to start a new group. This cannot be undone; save to Excel first if you need to keep the current data. |
Entity diagram
The Entity Diagram tab produces a visual map of the group structure. Entities appear as nodes; directorial, ownership, and other key relationships appear as labelled edges between them.
Click Regenerate from entered data to generate or refresh the diagram. The Structure Details summary table appears below it, listing all relationships by entity type (Companies, Trusts, SMSFs, UBOs) with column widths and row shading.
- Only people linked to at least one entity appear as nodes. Unlinked register entries are not shown.
- Representative relationships do not appear as diagram edges. They are listed in the Structure Details table.
- The diagram sizes to fit the group. For large groups, it scrolls horizontally.
Printing and filing
Once CDD capture is complete, use Print / Save as PDF to produce a file-ready record. The PDF covers all group details, entity CDD, risk ratings, the acceptance decision, and the sign-off section.
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Complete all entity tabs and the Customer Acceptance Decision section. |
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Click Print / Save as PDF. |
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Save the PDF to your document management system and file it against your firm's AML/CTF program. |
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Also save the Excel file as your working copy for future updates and monitoring. |
Frequently asked questions
Do I need to use this tool for every client?
Only for clients who are designated services recipients under the AML/CTF Act from 1 July 2026. Your firm's AML/CTF program should define which relationships require CDD and at what level.
I refreshed the page and lost my data. Can I recover it?
No. Data not saved to Excel before a refresh or tab close cannot be recovered. Save to Excel at the end of every working session.
How is the preliminary risk indication calculated?
The tool combines ratings across risk factors using your configured methodology to produce a preliminary indication. Treat it as a starting point. Your compliance officer should review and override the rating where judgement or additional context calls for it.
What happens to my Excel files when the full CDD module releases?
BGL plans to provide an import path so interim CDD records can move into Firm Verify when the automated module is available. Details will be confirmed closer to release.
A sanctions match was found. What do I do?
Pause the engagement immediately and escalate to your AML/CTF Compliance Officer. Do not proceed with onboarding. Adverse media findings are separate: they require investigation and assessment before you determine the appropriate response under your AML/CTF program.
Can multiple staff members work on the same group at once?
No. The tool is single-user within a browser session. Only one person should have the Excel file open for editing at a time to avoid overwriting each other's work.
This article covers the Firm Verify Group CDD Interim Tool (Beta 4, July 2026; updated Beta 5, July 2026). For questions about your AML/CTF obligations, refer to current AUSTRAC guidance or your compliance adviser. This tool is a data-capture aid and does not constitute legal or compliance advice.