From 1 July 2026, lawyers, accountants, conveyancers, real estate agents and potentially buyer’s agents will be required to comply with the Government’s new Anti‑Money Laundering and Counter‑Terrorism Financing (AML/CTF) obligations. One aspect of the reforms that may help reduce duplication is the use of reliance agreement.
What is a Reliance Agreement?
A reliance agreement allows one reporting entity to rely on customer due diligence (CDD) checks completed by another reporting entity, rather than repeating the same checks.
For example, in a property transaction, a client may need to engage both a lawyer and a real estate agent. Instead of providing the same identification documents multiple times, one party may be able to rely on checks already completed by the other.
Why does reliance matter?
Reliance can help streamline onboarding, reduce administrative burden and improve the client experience where multiple regulated professionals are involved in the same transaction.
However, reliance can only be used in appropriate circumstances and between eligible entities regulated under Australia’s AML/CTF framework (or equivalent overseas laws).
Reliance vs Outsourcing
Reliance should not be confused with outsourcing. While certain compliance tasks can be outsourced, the reporting entity remains responsible for meeting its AML/CTF obligations. Reliance applies only where one eligible regulated entity relies on checks completed by another.
As the reforms approach, businesses should review their compliance processes and consider whether reliance agreements may assist in reducing duplicated customer due diligence requirements.
As the reforms approach, businesses should review their compliance processes and consider whether reliance agreements may assist in reducing duplicated customer due diligence requirements. The costs associated with the new AML/CTF reforms varies from provider to provider, so it is important to consider the best solution for your business.
For more information about AML/CTF compliance, reliance agreements, or how FC Lawyers can work with referral partners to streamline the onboarding process for mutual clients, please contact our team. Our team have undertaken extensive AML/CTF training so we can ensure peace of mind when looking after mutual clients through various legal processes and services.
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