Can the agent's VOI be reused for the solicitor's CDD?

People search “reuse VOI for CDD” when a solicitor has been emailed the selling agent’s VOI pack and asked not to trouble the client again. Checked against AUSTRAC’s initial customer due diligence overview on 4 October 2026. This is general information, not legal advice. This page does not reproduce that guidance. The general split is on VOI versus CDD. The lawyer’s own checks are on AML checks for lawyers. The sector map is /tranche-2.

Two files that look like one PDF

The agent collected identity for the agency’s process. That process may be VOI, the agency’s own CDD, or a mix the email does not label. Your firm has a different program, a different designated service, and a different customer file. Saving their PDF into your matter does not tick your program.

You may use a copy as a prompt for what to look at. You still collect and verify what your program names. If someone is proposing true reliance, that is a written arrangement your program allows, not a courtesy attachment. This page does not draft that arrangement and does not say the attachment creates one.

• Label the attachment. Write “agent VOI, not our CDD” on the file note. A silent save becomes a false record.
• Match the person. The name on the agent’s form may not be the customer your retainer names.
• Do your risk rating. Their comfort with the client is not your rating under your program.
• Send your own link. The client can complete your check even if they already sat with the agent.

What arrived in the email

Open the attachment once and sort it. Most “please don’t ask again” emails contain one of four things. Only one of them is even a candidate for a later reliance conversation, and even that candidate is not reliance until the arrangement exists.

Where the VOI-reuse page stops

This page is the solicitor looking at an agent’s VOI. It is not the full VOI-versus-CDD explainer and it is not the lawyer compliance guide. Those are VOI versus CDD and AML checks for lawyers. FreeAML does not accept the agent’s pack as a completed check.

The firm suite is A$0. The firm emails the client a link and the 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 relying on an agent’s VOI pack, and that pack is not a prepaid check. Confirm the live amounts on FreeAML pricing. FreeAML does not treat an agent’s VOI pack as your customer due diligence.

Frequently Asked Questions