AML Customer Identity Verification for Mortgage Brokers

To complete anti-money laundering (AML) identity verification for a mortgage application, follow the lender’s authorised method and return the required evidence. Record consent, resolve exceptions through the instruction owner and keep confirmation that the check is complete.

A successful digital check is one part of the file. It doesn’t establish loan approval or automatically complete the separate identity requirements for a property transaction.

Separate Customer Verification From Property VOI

Customer identity verification establishes who the applicant is for the lender’s customer checks. Property verification of identity (VOI) supports a land-title transaction. Separate their purposes before collecting documents, even when a lender’s form covers both.

Know your customer (KYC) checks help a lender understand its customer and the relationship. Identity verification (IDV) is the identity-checking part. In digital identity terminology, identity proofing is the wider process of establishing an identity, validating evidence and connecting it to the person presenting it.

Check	Purpose	Responsible party	Evidence and completion record
Customer identity verification	Establish the applicant’s identity for the lender’s customer checks	Lender sets the instruction and decides whether its requirement is satisfied	Authorised identity documents or digital results, with consent and the lender’s required confirmation
Wider customer due diligence	Understand the customer and assess financial-crime risk	Reporting entity applies its programme	Identity and relevant ownership information, screening results and risk decisions
Identity proofing	Establish an identity and connect the evidence to its holder	Organisation operating the identity process	Validated attributes and evidence of the connection to the person
Property VOI	Establish identity for the property transaction	Party responsible for the applicable land-title process	Evidence and certification required by that process

An anti-money laundering check in Australia can involve more than a passport comparison. Under its programme, the lender checks identity and relevant beneficial owners, the people who ultimately own or control a customer. It also checks sanctions designations and politically exposed persons, people with specified prominent public functions or relevant connections.

The Australian Transaction Reports and Analysis Centre (AUSTRAC) describes these customer due diligence checks. You gather the evidence the lender requests. The lender applies its screening and risk rules, including any further review of a possible match.

A lender-directed check alone doesn’t make every brokerage an AUSTRAC reporting entity. AUSTRAC bases that status on providing designated services with the required Australian link. For the service-based assessment, use the mortgage-broker AML and counter-terrorism financing (AML/CTF) guide.

Incorrect: record a customer IDV pass as proof that the property VOI is complete. Correct: record the customer check and the property VOI evidence separately, with their own completion requirements.

Confirm the Instruction Owner and Required Check

Start with the instruction for this applicant and product, including who accepts the evidence. An aggregator can distribute a lender’s instruction, so record both the sender and the lender whose requirement you’re completing.

1. Identify each person to be checked and their role. Include a borrower, guarantor or representative only as the instruction requires.
2. Save the current instruction, its version and effective date. Record the lender, product and application reference beside it.
3. Identify the check type and approved method. Distinguish customer identification, electronic matching and any separately required property VOI.
4. Record the accepted documents and any alternate method. Include who is authorised to certify or review evidence where that method requires it.
5. Record the evidence recipient, authorised transfer channel and escalation contact. Before collecting data, resolve an instruction that lacks these details with its owner.

Continue when the instruction identifies the applicant, method and destination clearly. A document list for a bank account or another lender isn’t authority for your mortgage application.

ANZ, Westpac and Bankwest Instructions

As at October 2026, ANZ’s public Identification by Certified Copy for Individual form requires Parts A, B and C, with certified copies attached. The individual signs in the authorised certifier’s presence. Its document options are one primary document type or two different secondary types, with linking evidence for changed details.

That ANZ form identifies the eligible certifiers and document categories. Use it when the ANZ instruction for your application specifies certified copies. Return the package to the recipient named in the application instruction and retain confirmation of receipt or completion.

As at October 2026, Westpac’s public Verification of Identity Certificate names face-to-face interviews and Smart Verify. Its permitted verifier is a Westpac Group staff member or, for broker-originated applications, a Westpac-accredited broker. The form requires the relevant evidence attachment and verifier declaration.

For Westpac’s Smart Verify method, the certificate requires an ID Verification Report with a completed-pass status. Face-to-face verification requires copies of the original documents, with broker certification where applicable. Use Westpac’s escalation procedure when the form’s required details can’t be verified.

As at October 2026, Bankwest’s public Verification of Identity form separates in-person and virtual identification. It requires original documents to be sighted for the in-person route. Its virtual declaration is tied to extenuating circumstances, so it doesn’t authorise video identification for every application.

Bankwest’s form also has electronic-identification consent choices, an Australia Post alternative and a separate property VOI attestation where needed. Its transfer options include the secure DocBox system. Keep each applicable requirement separate and use the route authorised for your file.

Government Identity Services Have a Different Role

The Identity Verification Services Act 2023 is in force, as at October 2026. The Act governs identity-service facilities and the collection, use and disclosure of information for those services. It doesn’t supply an ANZ, Westpac or Bankwest mortgage document checklist.

IDMatch explains the government matching services. The Document Verification Service (DVS) checks document details against government records. It doesn’t check facial images, so a document match and a face comparison are different results.

Collect Documents, Consent and Digital Evidence

Electronic identity verification captures and checks identity evidence through an approved digital process. Depending on the instruction, it can involve document details, issuer-record matching or an authorised facial check. Uploading a photograph alone doesn’t show that those checks have occurred.

1. Give the customer the required collection notice and consent wording before starting. Explain the purpose, information recipients and consequences of declining the method.
2. Record the consent response and its time. Where DVS is used, IDMatch requires express consent, which can’t be inferred from silence or an opt-out arrangement.
3. Request only the documents the instruction permits. Check the required names, document validity and whether both sides or linking evidence are needed.
4. Use the approved capture or checking process. Keep the result reference, status and any report the instruction requires.
5. Prepare the evidence for the authorised recipient. Use the specified secure channel and retain a submission reference.

Stop when consent is absent or withdrawn, a document is unsupported or the names don’t match reliably. Follow the authorised alternate route instead of changing the consent record or substituting another document yourself.

Collect only what the instruction requires. If the approved process sends evidence directly to the lender, don’t create an additional local copy without a defined file requirement. Restrict access to authorised staff and use the brokerage’s permitted retention schedule.

For each electronic check, your record needs the consent wording and response, documents used, method, result and evidence-transfer reference. Capture failures and reviewer decisions belong in that record too. Keep full document numbers and biometric media out of ordinary email subject lines and general task notes.

The best identity verification method for a file is one the instruction owner accepts and the customer can complete reliably. An approved in-person or certified-copy route can be the right choice when a digital method isn’t available. Compare identity verification software separately when selecting a platform for your brokerage.

Handle Biometric, Liveness and Exception Results

Biometric identity verification compares a person’s physical characteristics, such as their face, with identity evidence. A facial match is evidence for the instructed check. The lender still decides whether the evidence satisfies its customer-verification requirement.

Control	What it contributes	What the broker records
Facial comparison	Comparison between the captured face and the authorised reference image	Result and report reference required by the instruction
Liveness detection	Evidence intended to distinguish a live capture from a replay or presentation attack	Capture status and any failure code
Near-field communication (NFC)	Reading data from a supported identity-document chip at close range	Chip-read result where the approved method uses it
Automated or artificial intelligence (AI)-assisted checks	Document extraction, matching or detection of possible manipulation	System result and referral status
Anti-deepfake controls	Checks for generated or altered media and injected images or video	Alert and escalation reference

NFC requires a supported document and device. The Australian Government’s passport-chip guides illustrate chip reading. They don’t establish that a particular lender accepts NFC for a mortgage application.

Facial forensics examines signs of manipulation in facial images or video. Generative AI can create or alter media used in identity checks. The US National Institute of Standards and Technology’s digital identity guidance describes those attacks and controls for forged media and digital injection.

That technical guidance explains the risks, rather than setting an Australian lender’s rules. A liveness pass doesn’t establish that every manipulation control passed. Keep the distinct results the approved process produces.

Symptom	Diagnostic check	Corrective action
Poor or incomplete capture	Check glare, focus and missing document edges against capture instructions	Retry only within the permitted process
Unsupported document or failed chip read	Check the approved document list and device requirements	Use the authorised alternate document or method
Name mismatch or no match	Compare entered details with the document and any linking evidence	Correct a transcription error or refer the unresolved mismatch
Liveness failure	Check the permitted capture conditions and result code	Refer repeated or unexplained failures for manual review
Possible manipulation or injected media	Preserve the system alert and relevant reference	Stop the check and escalate through the designated channel
Customer can’t consent to or complete the digital method	Check the approved alternate pathway	Arrange the accepted assisted or in-person route

Describe the observed result, such as an unsuccessful match or a system alert. Those results don’t prove that the customer is fraudulent. Don’t edit an image to make a check pass or move identity data into an unapproved AI tool.

A Name-Mismatch Example

In this fictional example, Casey’s application uses a married surname and the identity document uses an earlier surname. The broker records the mismatch and requests linking evidence only if the instruction permits it. The instruction owner then reviews the evidence and confirms the accepted next step.

The file records the mismatch, referral and final decision. It stays open until the authorised reviewer confirms completion. A later technical pass doesn’t erase the original exception.

Record, Escalate and Complete the Handoff

Complete the handoff by returning the specified evidence and retaining confirmation of its acceptance or completion. Sending the package is a separate event from the lender confirming the check is complete.

Use one record for each person and instructed check. The fields below give the next staff member enough information to follow the file without duplicating identity documents.

Record field	What to save
Instruction	Owner, product, application reference, version and effective date
Person	Applicant reference and role in the application
Consent	Wording or version, response and collection time
Evidence	Documents requested and used, with permitted references or attachments
Method and result	Approved method, date, system status and report reference
Exception	Observed problem, action taken and whether it remains open
Review	Reviewer’s identity, decision and escalation recipient
Handoff	Authorised destination, evidence sent, time and submission reference
Completion	Receipt, remaining conditions and confirmation that the instructed check is complete

1. Check the package against the exact instruction. Resolve missing signatures, unreadable evidence and unresolved exceptions before marking it complete.
2. Return only the required evidence through the authorised channel. Keep the transfer reference in the restricted broker file.
3. Confirm receipt or completion with the recipient. If receipt leaves review outstanding, keep the check open and assign a follow-up owner.
4. Record the final confirmation and retain the permitted audit evidence. Keep any separate property VOI or loan-approval requirement open until its own conditions are satisfied.

A technical pass doesn’t satisfy every AML/CTF obligation or decide the credit application. Close the customer-verification task only when its required evidence and completion confirmation are present. Leave any separate review or transaction requirement with a named owner and next action.