A new feature from Instant Compliance
Your clients have already proven who they are. Stop making them do it again.
When multiple professionals are involved in the same transaction — an agent, a conveyancer, a lawyer, an accountant — each one has an obligation to verify the client's identity under the AML/CTF Act. Without Reliance, that means the same person submitting the same documents over and over again. Instant Compliance Reliance changes that. And because it runs on the Instant Compliance network, you are not locked into a relationship with a single counterparty — any firm on the platform can be your reliance partner.
Start freeLaunching July 2026. Available to all Instant Compliance subscribers.
The problem
- 1
The agent asks for ID.
The vendor or buyer submits their passport and proof of address to meet the agent's AML/CTF obligations.
- 2
The conveyancer asks for ID.
The same client receives another request — different platform, different form, same documents.
- 3
The lawyer asks for ID.
If a lawyer is involved in the transaction, the client receives a third request.
- 4
The accountant asks for ID.
If the client's accountant is advising on the transaction, a fourth request arrives.
One transaction. Four identity requests. Same client. Same documents. Every time.
This is not a hypothetical. It is what happens on every property transaction in Australia from 1 July 2026 — unless the professionals involved use Reliance.
Why every firm still has to act
Reliance is a legal mechanism built into the AML/CTF Act. It is not a shortcut. It is the correct way to do this.
From 1 July 2026, every reporting entity — every real estate agent, conveyancer, accountant, and lawyer providing a designated service — must conduct customer due diligence on their clients. That obligation cannot be delegated or waived. What the law does allow, under section 37A of the AML/CTF Act, is for one firm to rely on the customer due diligence carried out by another firm — provided both firms are reporting entities, a formal reliance arrangement is in place, and the relying firm still forms its own risk view.
“A reporting entity may rely on a customer due diligence procedure carried out by a reliable third party in respect of a customer.”
This is not a new mechanism. Banks and financial institutions have used reliance under the AML/CTF Act since 2006. Tranche 2 extends the same framework to real estate agents, conveyancers, accountants and lawyers.
What reliance means: your client may only need to complete identity verification once, with the originating firm. That verified package is then shared with the relying firm through Instant Compliance.
What reliance does not mean: any firm can skip its own risk assessment, PEP and sanctions screening, or record-keeping obligations. Every firm still does its own due diligence. Reliance simply removes the need to ask the client to re-submit documents that have already been verified.
AML/CTF Act · AUSTRAC
Your CDD obligations remain yours.
Each firm must still identify and verify the customer, screen for PEPs and sanctions, assign a risk rating, and retain records for 7 years. Reliance means you receive a verified identity package — it does not mean you outsource your judgement.
Penalties up to $33M for corporates apply for serious contraventions of the AML/CTF Act. Reliance reduces operational burden — it does not provide immunity from your own obligations.
Privacy Act · OAIC
Fewer copies of sensitive documents.
When you rely on another firm's CDD through Instant Compliance, you hold the reliance acknowledgement — not a copy of the client's passport or driver's licence. The originating firm holds the verified identity records. Your Privacy Act obligations in relation to that identity data are significantly reduced. Reporting entities that handle personal information for AML/CTF purposes should review their Privacy Act obligations, including how long they retain identity documents.
The OAIC has published specific guidance for reporting entities under the AML/CTF Act. Instant Compliance's standard collection notice is drafted to meet those requirements.
How reliance works in Instant Compliance
Six steps. Your client does one. Every firm stays fully compliant.
Sign a standing reliance agreement
Your firm and the originating firm sign a standing reliance arrangement through Instant Compliance. This covers all future transactions between the two firms. Sign once — it applies to every matter.
Client completes identity verification
The originating firm sends the client a KYC request through Instant Compliance. The client verifies their identity once — photo ID, liveness check, address confirmation.
Verification is completed and packaged
Instant Compliance verifies the client's identity electronically, screens for PEPs and sanctions, identifies any beneficial owners for company clients, and packages the verified CDD record.
Package delivered to your firm
The verified CDD package lands in your Instant Compliance account automatically. No manual handoff. No email attachments. No chasing.
Review, screen, and form your own risk view
You review the package, run your own PEP and sanctions screen against current lists, assign your own risk rating, and acknowledge the reliance. This step is yours — it cannot be delegated. Your obligations are met. Your audit trail is complete.
Ongoing monitoring continues as normal
Reliance covers the initial CDD. Your ongoing monitoring obligations — transaction monitoring, periodic review, and suspicious matter reporting — continue as they would for any client.
The client is not asked to re-submit documents. They may be notified that their verified information has been shared with another firm involved in their transaction, consistent with the collection notice they received at the time of verification.
Who reliance is for
Reliance works across every profession involved in a transaction.
Any two reporting entities involved in the same transaction can establish a reliance arrangement, provided both are registered with AUSTRAC and a formal agreement is in place. Instant Compliance manages the agreement, the package sharing, and the audit trail — across all four of the major professions affected by Tranche 2. You are not locked to a single counterparty: as more firms join the Instant Compliance network, the more transactions you can handle through Reliance.
Real Estate Agents
You are the seller's agent. The buyer's conveyancer is on Instant Compliance.
Under the AML/CTF Act, you must conduct CDD on both the seller (your client) and the buyer (the counterparty to the transaction). That means two sets of identity checks on every sale. With Reliance, if the buyer’s conveyancer is also on Instant Compliance and has already verified the buyer’s identity, you can rely on that verification. The buyer does not receive a second request from your agency. The verified package arrives in your account automatically, and you complete your own risk assessment.
What you still do yourself
- Assign a risk rating for the buyer.
- Screen for PEPs and sanctions against current lists.
- Retain the reliance record for 7 years.
- Conduct ongoing monitoring through to settlement.
Conveyancers
You are the buyer’s conveyancer. The selling agent is on Instant Compliance.
You are instructed by the buyer. The selling agent has already verified the buyer’s identity as part of their own CDD obligations. With Reliance, that verified package is shared with you through Instant Compliance — and your client does not need to go through the verification process a second time. The same applies in reverse: if you have verified a client’s identity and a real estate agent, lawyer, or accountant involved in the same transaction is also on Instant Compliance, you can share the package with them under a standing arrangement.
What you still do yourself
- Review the package and confirm it meets your own CDD standards.
- Run your own PEP and sanctions screen.
- Assign your own risk rating.
- Retain records for 7 years, and monitor through to settlement.
Accountants
You are advising a client on a property purchase or business sale. Their lawyer is on Instant Compliance.
Accountants providing designated services — including assisting with the purchase or sale of real property or a business entity — must conduct CDD on their clients. Where the client’s lawyer or conveyancer has already verified their identity through Instant Compliance, you can rely on that verification rather than asking the client to go through the process again. This is particularly valuable for accounting firms with long-standing client relationships. A client who has been with your firm for years and is now buying an investment property should not need to re-prove their identity to you — but your obligations still apply, and Reliance is how you meet them efficiently.
What you still do yourself
- Review the verified package.
- Conduct your own risk assessment for the service you are providing.
- Screen for PEPs and sanctions.
- Retain records for 7 years.
Lawyers
You are acting for a client in a property transaction or business sale. The conveyancer or agent is on Instant Compliance.
Law firms providing designated services — including conveyancing, business sales, trust creation, and managing client funds — must conduct CDD on their clients from 1 July 2026. Where another reporting entity involved in the same matter has already verified the client’s identity through Instant Compliance, your firm can rely on that verification. Reliance is particularly useful for law firms acting on both sides of a transaction, or where the client is also represented by an accountant or financial adviser who is already on Instant Compliance.
What you still do yourself
- Review the verified package.
- Apply your own risk assessment to the specific legal service.
- Screen for PEPs and sanctions.
- Retain records for 7 years, and monitor for the duration of the matter.
What changes
Before and after Reliance.
| Obligation or task | Without Reliance | With Instant Compliance Reliance |
|---|---|---|
| Client identity verification | Each firm sends its own request | Client verifies once with the originating firm |
| PEP and sanctions screening | Each firm runs its own screen independently | Each firm still screens — but against the shared verified profile |
| Risk assessment | Each firm completes independently | Each firm still completes independently — this is not shared |
| Storing verified identity records | Each firm stores its own copy of documents | Originating firm holds the verified record; relying firm holds the reliance acknowledgement |
| Privacy Act exposure on identity documents | Each firm holds passport and licence copies | Relying firm holds the acknowledgement only — not the underlying documents |
| Chasing clients for documents | Your team's responsibility | Originating firm's responsibility |
| Audit trail | Manual, inconsistent across firms | Immutable, timestamped, and retained for 7 years in Instant Compliance |
| Standing agreement management | Manual paperwork, easy to let lapse | Managed in Instant Compliance — renewal reminders, material change triggers |
| Client experience | Multiple requests, multiple platforms, frustration | One request, one platform, one experience |
Client identity verification
Without Reliance
Each firm sends its own request
With Instant Compliance Reliance
Client verifies once with the originating firm
PEP and sanctions screening
Without Reliance
Each firm runs its own screen independently
With Instant Compliance Reliance
Each firm still screens — but against the shared verified profile
Risk assessment
Without Reliance
Each firm completes independently
With Instant Compliance Reliance
Each firm still completes independently — this is not shared
Storing verified identity records
Without Reliance
Each firm stores its own copy of documents
With Instant Compliance Reliance
Originating firm holds the verified record; relying firm holds the reliance acknowledgement
Privacy Act exposure on identity documents
Without Reliance
Each firm holds passport and licence copies
With Instant Compliance Reliance
Relying firm holds the acknowledgement only — not the underlying documents
Chasing clients for documents
Without Reliance
Your team's responsibility
With Instant Compliance Reliance
Originating firm's responsibility
Audit trail
Without Reliance
Manual, inconsistent across firms
With Instant Compliance Reliance
Immutable, timestamped, and retained for 7 years in Instant Compliance
Standing agreement management
Without Reliance
Manual paperwork, easy to let lapse
With Instant Compliance Reliance
Managed in Instant Compliance — renewal reminders, material change triggers
Client experience
Without Reliance
Multiple requests, multiple platforms, frustration
With Instant Compliance Reliance
One request, one platform, one experience
Every firm retains full responsibility for its own AML/CTF obligations. Reliance does not transfer liability — it enables efficient sharing of verified identity information while each firm maintains its own compliance record.
How it is built
The infrastructure behind Reliance.
Reliance is not a simple document-sharing feature. It is a compliance workflow built around the specific legal requirements of section 37A of the AML/CTF Act and section 6-29 of the AML/CTF Rules. Every component is designed to ensure that both the originating firm and the relying firm can demonstrate to AUSTRAC that their obligations were met.
Standing agreement engine
Instant Compliance manages the standing reliance arrangement between your firm and your counterparty firms. Agreements are executed digitally, stored on the platform, and flagged for review when they approach the end of their validity period or when a material change occurs. You sign once — the system manages the rest.
Structured CDD package sharing
When a verified CDD package is shared under a reliance arrangement, it is delivered as a structured record — not an email attachment or a PDF. The package includes the identity verification result, the PEP and sanctions screening outcome, and the beneficial ownership information where applicable.
Re-screening on import
When your firm receives a reliance package, Instant Compliance automatically re-runs PEP and sanctions screening against current lists at the time of import. Screening lists change daily. A clean result from two weeks ago may not reflect today’s position. This step is not optional — it is built into the workflow.
Immutable audit trail
Every reliance arrangement, every package delivery, every acknowledgement, and every re-screening result is recorded with a timestamp and retained for 7 years. If AUSTRAC ever audits your firm, you have a complete, verifiable record of how every reliance was handled.
Works across the network
Any two firms on Instant Compliance can establish a reliance arrangement. You are not locked into a bilateral relationship with a single counterparty. As more firms join the network, the value of your reliance capability grows.
Not on the platform? Still works.
You can rely on a firm that isn't on Instant Compliance.
As long as both firms are registered reporting entities and a formal reliance arrangement is in place, you can still rely on another firm's CDD. We give you a manual import workflow and a reliance acknowledgement record so it's properly documented — you just don't get the automatic package sharing, re-screening and audit trail that kick in when both firms are on the platform.
Refer a firm, earn check credits.
Reliance gets better the more of your network is on the platform — every arrangement runs automatically, with re-screening and a full audit trail. So when you refer a firm you work with and they join Instant Compliance, we'll add extra verification credits to your account. Free checks, on us — just for growing the network.
Common questions
What people ask about Reliance.
Does reliance mean my firm no longer has to do customer due diligence?
No. This is the most important thing to understand about reliance. Every firm that relies on another firm’s CDD remains fully responsible for its own obligations under the AML/CTF Act. Reliance means your client does not need to re-submit identity documents — it does not mean your firm can skip its risk assessment, PEP and sanctions screening, or record-keeping obligations. You still do all of those things. You simply do them using a verified identity package that has already been assembled by the originating firm.
Does my client need to consent to their information being shared?
Your client does not need to give separate consent for their verified identity information to be shared with another firm under a reliance arrangement. The sharing is authorised by the AML/CTF Act and AML/CTF Rules. However, your collection notice — the privacy notice your client receives when they complete identity verification — should inform them that their information may be shared with other regulated entities involved in their transaction. Instant Compliance’s standard collection notice includes this disclosure.
What if the other firm is not on Instant Compliance?
Reliance can still operate between firms on different platforms, provided both firms are registered reporting entities and a formal reliance arrangement is in place. However, the automated package sharing, re-screening, and audit trail features of Instant Compliance Reliance are only available when both firms are on the platform. For out-of-network reliance, Instant Compliance provides a manual import workflow and a reliance acknowledgement record.
Can I rely on a firm’s CDD if I am not sure their verification standards are adequate?
No — and this is a deliberate design decision in Instant Compliance. The relying firm must be satisfied that the originating firm’s CDD meets the required standard before reliance can be acknowledged. Instant Compliance prompts the relying firm to review the package and confirm this before the reliance is recorded. If the package does not meet your standard, you can request additional information or conduct your own verification instead.
Does reliance apply to ongoing monitoring, or just initial CDD?
Reliance applies to the initial customer due diligence — the identity verification, beneficial ownership identification, and initial PEP and sanctions screening. It does not extend to ongoing monitoring obligations. Each firm remains responsible for monitoring its own client relationships, conducting periodic reviews, and reporting suspicious matters independently.
Get started with Reliance
Ready to set up Reliance for your firm?
Instant Compliance Reliance is available to all subscribers from July 2026. Setting up a standing reliance arrangement with another firm takes less than five minutes. Book a demo and we will walk you through how it works end to end — the agreement, the workflow, the audit trail, and what your team needs to do on each matter.