Reliance or CoSec-performed CDD: which applies to your order?

When you order a company, trust, or SMSF through CoSec Partners, the AML/CTF treatment of the order depends on whether the customer’s due diligence can be relied upon or whether CoSec must perform it. There are three situations, and the order form resolves which one applies before you submit.

The first is where your firm has an active, approved reliance arrangement on file. In that case the order needs only a short per-order confirmation: you confirm that your firm has performed customer due diligence on the customer for this particular order, including identification, beneficial ownership, and screening, and that you will provide the records on request. There is no duplicate verification and no separate fee.

The second is where your firm is a reporting entity, an accounting or legal practice or a financial advisory firm, but has not yet set up an arrangement. Here the order form asks you to accept a reliance declaration for that order. We rely on it only where we are satisfied the conditions for case-by-case reliance are met, including your agreement to give us the customer information and verification records promptly; otherwise we carry out the customer due diligence ourselves. Setting up an arrangement in the portal turns this into a one-step confirmation on every future order.

The third is where the customer is not covered by reliance at all, for example an individual ordering directly, or a client whose firm is not a reporting entity. In that case there is no other firm whose due diligence CoSec Partners can rely on, so CoSec must collect and verify the customer information itself. A one-off AML/KYC Screening Fee, from $150 + GST ($165), is added to the order to cover identification and risk-based verification of the customer, the company’s beneficial owners and directors (or, for a trust, the trustee, settlor and beneficiaries), and screening for sanctions and politically exposed persons. Higher-risk customers may require enhanced due diligence at additional cost.

The reason for the distinction is that the obligation attaches to the designated service, not to the type of entity being formed. CoSec can only avoid performing CDD where there is a proper basis to rely on someone else’s; otherwise it carries the obligation and must do the work. The fee reflects that work, and applies only in the third situation.

The order form works out the treatment automatically from your firm type and your reliance status, so you see the correct option at checkout rather than having to choose. You can set up or review your firm’s arrangement at any time in the client portal’s AML Compliance tab.