AMLKitsCheck

Understanding Your Screening Result

This guide explains what your AMLKits Check screening result means and what steps you may need to take. It is general information only and does not constitute legal advice.

No match found

No match means the details you searched did not correspond to any person or entity on the sanctions and PEP databases screened. You should retain your compliance record for a minimum of 7 years. Screening is one part of your customer due diligence — you must still verify your client's identity and complete the other steps in your AML/CTF program.

Potential match found

A potential match means the name may correspond to a listed person or entity. It is not confirmation that your client is that person — names frequently coincide. Your first step is always to review whether the match genuinely relates to your client, using the additional details in the record (such as date of birth, country, and the lists involved). The right next step depends on the type of match.

Types of match

1. Sanctions match — the most serious

A sanctions match means the name appears on a list of persons or entities subject to legal sanctions. Dealing with a sanctioned person or entity can be a serious criminal offence under Australian law, with penalties including significant fines and imprisonment. If you identify a genuine sanctions match:

  • Do not proceed with the client or any transaction
  • Seek legal advice immediately
  • Consider your obligations to freeze assets and notify the Australian Sanctions Office (DFAT) and AUSTRAC

Even if you determine the match does not relate to your client, document your reasoning carefully and retain it with your compliance record.

Sanctions lists you may see

  • Australian Sanctions List (DFAT) — Australia's own Consolidated List, maintained by the Department of Foreign Affairs and Trade. This is the primary list Australian reporting entities must screen against. It includes persons and entities sanctioned under Australian autonomous sanctions and United Nations Security Council sanctions that Australia implements.
  • UN Security Council Sanctions — persons and entities sanctioned by the United Nations. Australia is legally required to implement these.
  • US OFAC Specially Designated Nationals (SDN) — the United States' sanctions list, maintained by the Office of Foreign Assets Control. Relevant where your client has any US nexus.
  • EU Financial Sanctions — sanctions imposed by the European Union.
  • UK HM Treasury Sanctions (OFSI) — the United Kingdom's sanctions list, separate from the EU's since 2021.

A match on any sanctions list should be treated seriously regardless of which country's list it is, because your obligations under Australian sanctions law and your AML/CTF program require you to identify and act on sanctions risk.

2. Politically Exposed Person (PEP) match — higher risk, but not prohibited

A PEP is someone who holds, or has held, a prominent public position — such as a senior politician, judge, senior public servant, senior military officer, or a senior executive of a state-owned enterprise — as well as their close family members and known close associates. PEPs are considered higher risk because their position could be abused for money laundering, bribery or corruption.

A PEP match does not mean you cannot act for the client. It means you should apply Enhanced Customer Due Diligence (ECDD) before onboarding, including: obtaining senior management approval; taking reasonable steps to establish the source of wealth and source of funds; and applying ongoing enhanced monitoring to the relationship.

PEPs are often categorised as:

  • Domestic PEPs — those holding a prominent position in Australia.
  • Foreign PEPs — those holding a prominent position in another country. These are generally treated as higher risk.
  • International organisation PEPs — senior figures in international bodies such as the UN or World Bank.
  • Family members and close associates — spouses, children, parents, business partners and others closely connected to a PEP, who carry associated risk.

3. Other list matches

Your result may also reference other data sources, such as public records (for example Wikidata) or watchlists of persons of interest. These provide context and may indicate a person warranting closer review, but are not in themselves sanctions or PEP designations. Treat them as prompts for further enquiry.

What to do in every case

Whatever the result, document your review and your decision — including a no-match result and your reasoning where a potential match was cleared as not relating to your client. Keep the compliance record for a minimum of 7 years.

Consider at each onboarding whether anything about the client or transaction gives rise to a suspicion that would require a Suspicious Matter Report to AUSTRAC.

If you are ever unsure how to treat a match, seek legal or compliance advice — the cost of getting it wrong can be severe.

This tool provides screening only. It does not verify your client's identity, and it does not constitute legal advice or advice on whether to accept a client. You remain responsible for your own compliance decisions.