Send us your AML docs is not a reliance arrangement

People search “AML document reliance between agent and lawyer” when a buyer’s agent emails a passport scan to the lawyer and both offices treat the scan as shared compliance. Checked against AUSTRAC’s overview of initial customer due diligence on 4 October 2026. This is general information, not legal advice. This page does not reproduce that guidance. Who runs CDD on a sale is who does CDD for a real estate agent. A visual check of a document is a different job from CDD, on VOI versus CDD. The sector map is /tranche-2.

A forwarded scan is not an arrangement

Agents and lawyers sit on the same sale and both feel the deadline, so one side asks the other to send whatever identity papers they already hold. That request can be polite, and it is not, by itself, reliance. Reliance is an arrangement the regime describes and your program either permits or does not. AUSTRAC’s initial CDD overview is the customer-due-diligence frame, and this page does not reproduce the reliance conditions.

Until that arrangement exists, each reporting entity follows its own program. The lawyer does not become compliant because the agency once sighted a document. The agency does not become compliant because the lawyer later ordered a check.

• Name what you received. An email attachment is information. Write who sent it and that it is not your check.
• Open your own program. If it requires a check, email the client your link. Do not tick a box because another firm already did something.
• Do not invent reliance in the subject line. “AML docs as agreed” does not create the arrangement. The arrangement is a decision the program allows, made on purpose.
• Keep VOI in its own box. Looking at a person and a document can be a verification-of-identity step in a conveyance. It is not the same label as customer due diligence, and it is not reliance either.

Email, reliance, and your own check

Three things arrive in the same inbox on settlement week. Only one of them is your customer due diligence.

Where the reliance page stops

This page is the email that is not reliance. It is not who must run CDD on the sale and it is not the VOI comparison. Those are who does CDD for a real estate agent and VOI versus CDD.

What the client pays

On FreeAML the firm suite is A$0. The firm emails the client a link. Verification is client-pays. On the public list a personal KYC check is A$20 and a company or trust KYB check is A$40. Use KYB when the customer is a company or a trust. Holding another firm’s PDF is not included in the firm suite, and the suite does not create a reliance arrangement. Confirm the live amounts on FreeAML pricing. FreeAML does not create a reliance arrangement or accept another firm’s documents as your CDD.

Frequently Asked Questions