What is a reliance arrangement under AML/CTF?

With AML/CTF obligations now becoming part of everyday property transactions since 1 July 2026, lawyers and conveyancers are starting to receive requests from other parties to those transactions, including real estate agents, that may not yet be familiar.

You may already have had questions along the lines of:

"Can you sign our reliance agreement?" or, "Can we use your KYC?"

And those requests may have prompted a few practical questions within your firm: what exactly is a reliance arrangement, and are you allowed to share your KYC checks with another party to the transaction?

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What is a reliance arrangement?

To be able to answer any of the above questions, it requires answering what a reliance arrangement itself is.

A reliance arrangement, also referred to as a reliance agreement, or formally as a customer due diligence (CDD) arrangement, allows one reporting entity to rely on customer due diligence information collected and verified by another reporting entity. That information may include the searches, checks, and documents that form part of the KYC process.

The mechanism exists to reduce duplication. In a property transaction, multiple parties may have CDD obligations for the same client, and a reliance arrangement provides a documented basis for one party to rely on the other's work rather than running the process again. The reverse can also apply, such as your firm relying on checks already completed by another reporting entity.

One important point to consider is that entering into a reliance arrangement does not transfer legal responsibility. The relying entity remains responsible for its own AML/CTF obligations and must continue to assess risk, obtain the required senior-manager approval, and review the arrangement regularly. See AUSTRAC's Quick guide — Reliance CDD arrangements for detail on what this involves.

How does a reliance arrangement work in a property transaction?

Say your firm is acting for a purchaser, Mr Banks, in a residential property transaction. You've already completed your AML/CTF checks for Mr Banks, his identity has been verified, source of funds confirmed and CDD documentation on file.

The selling agent, Ms Mitchell from Mitchell Property Group, contacts you. Her agency is also a reporting entity under the regime and needs to complete its own CDD for Mr Banks. Rather than putting him through the process a second time, Ms Mitchell asks whether she can rely on the checks your firm has already completed.

That's where a reliance arrangement comes in. If your firm agrees, the arrangement documents the basis on which Ms Mitchell's agency may rely on your CDD work, and what obligations each party retains as a result.

When might your firm receive a reliance request?

For lawyers and conveyancers with existing working relationships with real estate agents or other entities involved in the same transactions, reliance arrangements may start coming up as the regime beds in. If a client has already completed AML/CTF checks with your firm, an agent in the same transaction may ask whether they can rely on that work, or vice versa.

That's a practical and legitimate question. But before agreeing, it's worth making sure the arrangement is consistent with your own AML/CTF program and internal policies, and that you've considered any privacy and consent obligations that arise when sharing client information with a third party.

AUSTRAC has published detailed guidance on reliance arrangements on its website, which sets out the conditions that apply.

Where can you find a reliance arrangement template?

If your firm does decide to enter into a reliance arrangement, InfoTrack states its Compliance Centre includes a reliance arrangement template to help manage these requests within your existing workflows.

As always, firms should follow their own AML/CTF program and internal policies as well as independently consider any privacy and consent matters that may arise when handling reliance arrangements.

Final words

Navigating AML/CTF as a property lawyer means adding a new layer of process to an already busy practice. LEAP's dedicated Property team works with lawyers and conveyancers to make sure the platform reflects the reality of the work, including how compliance tasks sit within matter management rather than alongside it. Find out more about LEAP for property lawyers.