How we handle AML/CTF for your clients

Where we stand

CoSec Partners is enrolled with AUSTRAC as a reporting entity. The services we provide that are designated services under the AML/CTF Act include

• forming companies and other entities
• establishing trusts, including SMSFs
• providing a registered office or business address
• acting as, or arranging, a resident director or company secretary

We keep a written AML/CTF program and carry out customer due diligence in line with the AML/CTF Act, the AML/CTF Rules and AUSTRAC guidance. Our terms of service set out the full position.

What happens on each order

A single order can involve two reporting entities, your firm and us. The Act lets one rely on the customer due diligence the other has done, so the client is not put through it twice. The order form works out which of these applies from your firm type and your reliance status, so you never have to choose.

Setting up a reliance arrangement

It takes a few minutes and you only do it once for the whole firm.

1. Sign in to the client portal with your work email, or register if you do not have access yet.
2. Open the AML Compliance tab.
3. Confirm your firm is a reporting entity and enter your AUSTRAC enrolment details. If enrolment is still pending you can say so and add the number later.
4. Confirm you have an AML/CTF program, do customer due diligence including beneficial ownership, and have a compliance officer.
5. Agree that we can rely on your due diligence, that you will give us the client’s details before we act, and that you will send copies of the verification records within one business day if we ask.
6. Submit. A senior person at CoSec reviews it, checks your enrolment and approves it.

Once approved, the arrangement covers everyone at your firm who orders with their work email. It runs for twelve months and the portal prompts you to renew. You can update it at any time, for example when your enrolment number comes through or your compliance officer changes, and you can withdraw it from the same tab.

When we verify the client ourselves

Even with an arrangement in place, we do our own due diligence, and may pause an order until it is done, where

• the client is a politically exposed person or close associate, is subject to sanctions, is based in a high-risk jurisdiction, or has an unusual or complex ownership structure
• the service is provided to the client directly rather than through your firm, such as a registered office address held in our name
• something gives us reasonable grounds for suspicion
• the law or AUSTRAC guidance requires us to do it ourselves

Registered office addresses

Providing a registered office address is a designated service, and unlike a company registration it continues for as long as the address is held. Many firms are moving client addresses off their own office for that reason. When a client takes our address, the client contracts with us and we are the reporting entity for that service, so we carry the due diligence, the ongoing monitoring and the records. Our address services page explains how moving a book of addresses works.

What reliance does and does not change

• Reliance removes duplicated work. It does not move responsibility. Your firm stays responsible for the due diligence it does and tells us about, and we stay responsible for our own obligations.
• The firm that did the due diligence keeps the records for at least seven years and must be able to produce them when asked.
• Each firm handles its own suspicious matter reporting. Neither of us tells the client about a report, because tipping off is an offence.

What we do not do

We are not AML consultants. We do not prepare, review or sign off your firm’s risk assessment or AML/CTF policies, and nothing on this page is AML advice. For your own program, start with AUSTRAC’s free guidance and starter kits, and talk to your professional body or an AML specialist. What we do is make sure the entities we form and the addresses we hold for your clients are handled properly, without verifying the same person twice.

Common questions