1. What is ‘Safe Harbour’ in AUSTRAC’s AML/CTF regulations?
‘Safe Harbour’ is a simplified customer identity verification process under AUSTRAC’s AML/CTF rules. It allows law firms to verify individual clients using reliable documents or electronic data sources without requiring enhanced due diligence (EDD), provided the individual is medium or low risk for money laundering or terrorism financing.
For official AUSTRAC guidance on Safe Harbour and customer identification, visit:
🔗 AUSTRAC: Customer Identification & Safe Harbour
2. Why should a law firm use ‘Safe Harbour’?
Law firms benefit from ‘Safe Harbour’ because it:
✔ Simplifies compliance – Reduces the steps required for identity verification.
✔ Provides legal protection – Ensures firms meet AUSTRAC's customer due diligence (CDD) obligations.
✔ Speeds up onboarding – Minimizes friction for both law firms and their clients.
✔ Establishes a clear compliance framework – Ensures law firms follow risk-based identity verification.
3. Are PEP checks mandatory under ‘Safe Harbour’?
✅ Yes, PEP (Politically Exposed Person) checks are mandatory.
Even when using ‘Safe Harbour’ procedures, law firms must have risk-based procedures to identify PEPs before providing services or as soon as possible afterward. AUSTRAC requires law firms to determine whether a customer or beneficial owner is a PEP as part of their customer due diligence (CDD) obligations.
For detailed guidance on identifying and managing PEPs, refer to AUSTRAC’s official guide:
🔗 AUSTRAC PEP Quick Guide (PDF)
4. Is biometric facial recognition mandatory for ‘Safe Harbour’?
❌ No, biometric facial recognition is not mandatory.
‘Safe Harbour’ does not require biometric facial recognition. Law firms can verify identities using traditional verification methods, such as:
Government-issued photo ID (passport, driver’s license)
Electronic verification (trusted databases)
Document verification (utility bill, bank statement)
However, biometric facial recognition can enhance security and provide additional assurance in higher-risk scenarios, such as for PEPs or Enhanced Due Diligence (EDD), but it is not required for ‘Safe Harbour’ compliance.
Realaml's Safe Harbour Solutions
At Realaml, we offer two Safe Harbour-compliant verification options, both of which include PEP & Sanctions Screening:
✔ Quick IDV (No Biometric Facial Recognition) – A fast, document-based identity verification method that can be sent to the client or completed directly by a legal professional.
✔ Face IDV (With Biometric Facial Recognition) – Uses AI-powered biometric facial recognition with liveness detection for additional security, ideal for high-risk verifications or Enhanced Due Diligence (EDD).
Learn more:
🔗 FAQ: Quick IDV vs. Face IDV – Which One to Use?
Looking for alternatives to Safe Harbour?
🔗 What Are the Alternatives to ‘Safe Harbour’?