Case-by-case reliance versus a written CDD arrangement

People search “AML reliance arrangement” when a conveyancer is offered a one-off “we already did the identity” from the agent on a single settlement. Checked against AUSTRAC’s AML/CTF program overview on 4 October 2026. This is general information, not legal advice. This page does not reproduce that guidance. A reporting group is a different structure, explained on reporting groups for related entities. The transfer work itself is on AML for conveyancers assisting a transfer. The sector map is /tranche-2.

A favour is not an arrangement

On a settlement, the other side’s firm often offers their identity pack “just this once.” That is case-by-case in the loose sense. It is not a written customer due diligence arrangement, and it is not a reason to leave your program blank. If you still do your own check, their pack is only a copy. If you want to rely on their outcome, the program has to allow that path and the arrangement has to exist before the file.

You stay responsible either way. Reliance, where it is permitted, does not move the customer off your book. A reporting group, where related entities formally group, is a third structure and it is not created by being on the same settlement. This page does not set the legal test for when reliance is available.

• Name the path on the file. Own CDD, written arrangement, or neither. “Agent helped” is not a path.
• Do not backdate a letter. An arrangement signed after settlement does not describe what you did on the day.
• Keep the risk decision. Their rating is not yours. Your program still says how this customer is rated.
• One file is not a policy. A favour you accept twice is a practice. Write it down or stop doing it.

Four things people call reliance

Use the same four labels every time a pack arrives. The conveyancer’s job is to pick the label before anyone marks the CDD line complete.

Where the arrangement page stops

This page sorts a favour from an arrangement. It is not how reporting groups are formed and it is not the transfer guide. Those are reporting groups for related entities and AML for conveyancers assisting a transfer. FreeAML does not draft the arrangement and does not rely on the other firm for you.

The firm suite is A$0. Your own check, if the program requires it, is client-pays.

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. The firm suite does not include a reliance arrangement, and a favour from another firm is not a check you have paid for. Confirm the live amounts on FreeAML pricing. FreeAML does not draft a reliance arrangement or approve case-by-case reliance.

Frequently Asked Questions