AML/CTF reliance: how we’ve built it into ordering and our terms

From 1 July 2026, the Tranche 2 reforms bring accountants and lawyers into Australia’s anti-money laundering and counter-terrorism financing (AML/CTF) regime as reporting entities, alongside the financial sector that has been covered since 2006. Company formation, trust establishment, registered office services, and nominee director appointments are all designated services, which means AML/CTF obligations now attach to much of the work we do together. Over the last few months we have rebuilt the way AML/CTF flows through our order process and our terms of use, so that compliance is built in rather than bolted on.

The starting point is that a single transaction can involve two reporting entities. When your firm instructs us to register a company or establish a trust, both your firm and CoSec Partners may have CDD obligations in relation to the same underlying client. Rather than both of us performing duplicate customer due diligence, the Act allows one reporting entity to rely on the customer due diligence another has carried out, provided the conditions in the Act and AML/CTF Rules are met, including a written arrangement approved by a senior manager, the ability to obtain the customer information and verification records promptly, and regular review of the arrangement. That principle of reliance is the foundation of our approach.

To make reliance practical, we have added an AML Compliance tab to the client portal where your firm sets up a written CDD reliance arrangement once. It records that your firm is a reporting entity, captures your AUSTRAC enrolment details so we can verify them rather than take them on trust, and confirms that you maintain an AML/CTF program, perform customer due diligence including beneficial ownership, and have appointed a compliance officer. It also records your consent for us to rely on your CDD, your agreement to give us the customer information before we act and to provide copies of the underlying verification records immediately, or within one business day, on request, and your commitment to tell us if any of that changes. A senior person at CoSec reviews and approves each arrangement before it becomes active.

For professional services firms, completing the form takes only a few minutes and only needs doing once. Sign in to the client portal using the Client portal link in the site header (if you do not yet have access, register with your work email), then open the AML Compliance tab. That tab is where your firm’s reliance declaration lives. If a member of your firm has not set one up yet, this is the form to complete; once it is approved it covers everyone at your firm who orders through us.

The reliance form walks you through each confirmation in turn. You confirm that your firm is a reporting entity under the AML/CTF Act; you enter your AUSTRAC enrolment details for us to verify; you confirm that you maintain an AML/CTF program, perform customer due diligence including beneficial ownership, and have appointed a compliance officer; and you give your consent for CoSec to rely on that due diligence, together with your agreement to give us the customer information before we act and to provide copies of the underlying verification records immediately, or within one business day, on request. Work through each section, submit the form, and it comes to a senior person at CoSec for review. You will see the arrangement move from submitted to approved in the same AML Compliance tab, and from that point every company, trust, and SMSF order your firm places shows only the short per-order confirmation. The button above takes you straight there.

Once your arrangement is approved, ordering changes in a simple way. Every order you place shows a short per-order confirmation instead of a full verification step: you confirm that your firm has performed customer due diligence on the customer for that order, and there is no AML/KYC Screening Fee. If your firm is a reporting entity but has not yet set up an arrangement, the order form asks you to accept a reliance declaration for that order. We will rely on it only where we are satisfied the legal conditions for case-by-case reliance are met, including your agreement to give us the customer information and verification records promptly; otherwise we will carry out the customer due diligence ourselves. And where a customer is not covered by reliance at all, for example an individual ordering directly or a client whose firm is not a reporting entity, CoSec performs the customer due diligence itself and a one-off AML/KYC Screening Fee, from $150 + GST ($165), is added to the order.

Reliance is not set-and-forget. An approved arrangement is active for twelve months, after which the portal prompts your firm to confirm the details are still accurate and renew. You can also update the arrangement at any time if your circumstances change, whether that is your AUSTRAC enrolment number coming through, a change of compliance officer, or a change in how you perform CDD. Updating it resubmits the arrangement for a quick re-confirmation.

We have also added AML/CTF reliance terms to our terms of service, and the per-order declaration links straight to them. They set out the basis on which we rely on your firm’s customer due diligence, your obligation to keep the records and to provide copies of the verification records immediately, or within one business day, on request, and the important point that reliance shifts the work, not the legal responsibility. Each reporting entity remains responsible for its own obligations under the Act.

That last point is worth being clear about, because it is easy to misread reliance as a transfer of risk. It is not. CoSec remains the reporting entity for the services we provide and is responsible for forming a reasonable belief that the due diligence we rely on is adequate, which is exactly why we review each arrangement rather than accepting it automatically. Your firm, equally, remains responsible for the customer due diligence it performs and represents to us. Reliance is a practical mechanism that removes duplication; it does not move liability from one party to the other.

If your firm instructs us regularly, the single most useful thing you can do is set up your reliance arrangement in the client portal, so your company, trust, and SMSF orders flow through with one confirmation rather than a declaration each time. If you are not yet certain whether your firm is a reporting entity, or how the obligations apply to the specific services you provide, that is a question for an AML specialist or your professional body rather than for us; AUSTRAC’s guidance and starter kit for accountants are the right first stop. What we can do is set up the reliance side so the same customer is not verified twice.