Digital onboarding has made verification of identity (VOI) faster for many firms, but not every client can or wants to complete the process online. Some clients are elderly, some are not confident with technology, some have no email address or computer, and some would rather not upload their identity documents to a digital platform.
This is one of the most common questions raised in our Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) Check-In sessions: how do you onboard a client who struggles with the digital process? You have more than one option. Under the Tranche 2 obligations that took effect for conveyancers and lawyers on 1 July 2026, you can keep the benefits of digital verification for most of these clients and fall back to a full paper process only where a client genuinely needs it. This article steps through three practical options, in order, from the one that keeps the most digital benefit to a paper pathway for the clients who need it.
Is in-person onboarding still compliant under Tranche 2?
Yes. In-person onboarding is compliant under Tranche 2: the reformed AML/CTF framework lets your firm collect customer information either online or on paper. For individuals, identity can be verified using reliable and independent documentation or electronic data, or a combination of both, such as a passport or driver’s licence, and their appearance can be checked against their photo identification in person. That means a client does not need an email address, smartphone, or digital identity account for your firm to complete customer due diligence (CDD).
There is also an important difference between AML/CTF identity verification and conveyancing VOI. A face-to-face VOI completed under the Australian Registrars’ National Electronic Conveyancing Council (ARNECC) Verification of Identity Standard may satisfy your conveyancing identity requirements, but AML/CTF onboarding goes further. Your firm still needs to complete the rest of CDD, including collecting relevant Know Your Customer (KYC) information, assessing customer risk, and completing Politically Exposed Person (PEP) and sanctions checks.
Your three options for onboarding a client who can’t go digital
Whichever option suits the client, the process runs through an AML Onboarding Order in the triSearch Compliance Centre, and the compliance record lands in the same place as every other client you onboard. Work down the list in order, and only move to the next option if the one before it will not work for that client.
Option 1: guide the client through the digital process together
Process the AML Onboarding Order as you normally would and let the request go to the client, then arrange a time for them to come in. In that meeting, you walk the client through each step on their own device or mobile phone. The client still completes everything digitally, with someone beside them to help. The system verifies the identification, the KYC form is completed, and PEP and sanctions screening runs as usual, so the whole record stays in the Compliance Centre with no extra handling.
Option 2: complete the checks on your computer with the client present
If the client cannot manage the steps on their own device, send the tasks to yourself and have the client come into the office. You then complete the steps on your own computer with the client alongside you, entering their details and asking them to present their identity documents. When you select the checks, there is an option to complete them in person, so you can enter the client’s answers into the KYC form on their behalf. The VOI still involves a digital upload of the identity documents, which means the system verifies them for you. That adds a layer of fraud detection that a visual check of documents on its own cannot offer, and it keeps the full digital audit trail intact.
Option 3: complete the process on paper and upload the records
For a client where neither option works, because they have no device, cannot attend the office with the right documents, or your firm’s procedures call for a standalone paper pathway, complete the process on paper and verify identity face to face. Collect the client’s full name, date of birth, residential address, and any other information your CDD procedures require, then check the client against their photo identification. From there, place an AML Onboarding Order for the client without sending them anything to complete, and have your staff upload the completed documents, the paper VOI, the onboarding form, and any supporting identification, directly into the order. PEP and sanctions screening can then be run from within the same order, using the information already collected. The client does not need to receive an email, click a link, or interact with the system at any point. For the detailed steps, see our guide to manually completing a VOI in the Compliance Centre.
Whichever option you use, the record lives in one place
A manual or in-person onboarding process carries the same obligations as a fully digital one. Your firm needs a clear record of the information collected, how identity was verified, and each CDD step completed, and that record generally needs to be kept for seven years after the business relationship ends or an occasional transaction is completed.
Running every option through an AML Onboarding Order means the record for that client sits alongside every other client you have onboarded through the Compliance Centre, ready to search and produce if your firm is ever subject to an AUSTRAC compliance assessment or an independent evaluation of your AML/CTF program. You can keep records elsewhere, electronically or in hard copy, but a single system means one place to look when a record needs to be called up months or years from now.
What if the client doesn’t have standard identification?
For clients who cannot go digital, the issue is how they complete onboarding, not whether they have acceptable identification. But what if a client also cannot provide the standard identification required under your CDD procedures?
The Australian Transaction Reports and Analysis Centre (AUSTRAC) provides alternative identification options. These can include referee statements or recently expired identification, depending on the client’s circumstances. Your firm needs to consider the additional risk and follow the alternative identification procedures set out in its AML/CTF program.
The key is to have more than one onboarding pathway.
Keeping onboarding flexible, but consistent
A good AML/CTF process does not assume every client can follow the same digital journey. Building these three options into your procedures means you can meet a client where they are, keep the stronger fraud detection that digital verification offers wherever possible, and still onboard the clients who need a paper pathway, all while holding the record to the same standard.
In the triSearch Compliance Centre, firms can upload a previously completed or face-to-face VOI rather than sending the client a new digital VOI request. That is the approach we would recommend for firms running both pathways: keep the client-facing step manual where the client needs it and keep the broader AML/CTF checks and records structured in one place. If you’d like to see how these options work in practice, book a walkthrough of the Compliance Centre.
The aim is not to force every client into a digital process. It is to make sure every client can be onboarded through a process that is practical, compliant, and properly documented.
Manual and in-person VOI: common questions
Can a client be onboarded without an email address?
Yes. AML/CTF obligations don’t require a digital onboarding process. You can have the client complete the checks in person on your computer, or complete the process on paper and upload the records to an AML Onboarding Order, so a client without an email address, computer, or smartphone can still be onboarded.
Can a client complete VOI and KYC in person at our office?
Yes. You can either sit with the client while they complete each step on their own device, or complete the steps on your own computer with the client present, entering their answers into the KYC form on their behalf. The identity documents are still uploaded digitally, so the system verifies them.
Does a face-to-face conveyancing VOI satisfy AML/CTF onboarding?
Not on its own. A face-to-face VOI completed under the ARNECC Verification of Identity Standard may satisfy your conveyancing identity requirements, but your firm still needs to complete the rest of customer due diligence, including KYC information, customer risk assessment, and PEP and sanctions checks.
How long do manual CDD records need to be kept?
CDD records generally need to be kept for seven years after the business relationship ends, or an occasional transaction is completed. Records can be kept electronically or in hard copy.
What counts as alternative identification?
AUSTRAC provides alternative identification options, which can include referee statements or recently expired identification. Your firm needs to consider the additional risk and follow the alternative identification procedures set out in its AML/CTF program.
triSearch provides software solutions for conveyancing processes. Users remain responsible for compliance with applicable laws and regulations.
