AICWA

❓ Is sending onboarding documents considered “offering a service” before CDD is complete?

A common question we are receiving is whether preparing and sending documents such as an appointment to act, CAF and Cost Disclosure could be considered “offering a service” before Customer Due Diligence has been completed.

The answer is no. These documents can be sent at the same time as the client’s CDD/KYC requirements, as this would generally form part of the onboarding process rather than progressing the settlement itself.

In practice, this may mean gathering the initial information first and deciding whether you wish to take on the matter. Once you are comfortable proceeding, you can send the client their CDD/KYC link and documents for signing at the same time.

Have you secured your ticket to the AICWA State Conference 2026?

This year, you can choose the experience that suits you best:

CPD Room – complete your 5 compulsory CPD points while hearing practical, industry-focused updates.

Breakout Room – explore business growth, wellbeing, professional development and future-focused thinking.

Whichever room you choose, the conference is designed to leave you informed, energised and ready for what comes next.

Why attend?

🔸 Learn something new
🔸 Connect with others in the industry
🔸 Complete your CPD points
🔸 Great excuse for a stay at Crown Perth

Join us for a full day of practical learning, fresh ideas and valuable connection.

📍 Crown Perth
📅 Saturday, 29 August 2026

Secure your ticket now!
👉 https://www.aicwa.com.au/eventdetails/38516/aicwa-state-conference-2026