When the Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) legislation was extended to lawyers, conveyancers, and real estate agents under the Tranche 2 reforms, most practitioners understandably focused on what was required of them. Fewer considered what was made possible. Embedded within that same legislation is a mechanism called Reliance, and the law firms that understand it now are already building structured referral relationships with real estate agents before the bulk of the profession has caught up.

What is Reliance under AML/CTF?

Reliance is a provision within the AML/CTF legislation that allows one reporting entity to rely on the customer due diligence checks completed by another, rather than conducting those same checks independently.

In practical terms, consider a home buyer in Australia. From 1 July 2026, that buyer will need to complete AML/CTF checks with their real estate agent, their lawyer or conveyancer, and potentially their buyer’s agent. Without Reliance, the client would need to submit and pay for the same identification documents and answer the same Know Your Customer (KYC) questions multiple times across the same transaction.

AUSTRAC recognised that this outcome was neither practical nor consistent with a sound client experience. The Reliance mechanism was designed specifically to address it. When a Reliance agreement is in place between two reporting entities, one party completes the required AML/CTF checks and the other relies on that report, eliminating duplication for the common client.

Reliance is not a product. It is a legislative mechanism. Any reporting entity operating under the AML/CTF Act can make use of it.

Who can enter into a Reliance agreement?

Any two reporting entities can establish a Reliance agreement, provided both are captured under the AML/CTF legislation and a written agreement outlining each party’s obligations is in place.

In property transactions, this most commonly applies to law firms and conveyancing practices entering agreements with real estate agencies. However, the mechanism is not limited to this pairing. Mortgage brokers, buyer’s agents, accountants, and commercial agents operating as reporting entities may also be parties to Reliance agreements where their services intersect with a shared client.

A law firm can hold Reliance agreements with multiple agencies simultaneously. Agencies can similarly hold agreements with multiple law firms or conveyancers. There is no legislative cap on the number of agreements a reporting entity may enter.

How does a Reliance agreement work in practice?

There are three stages to making Reliance operational.

Establishing the agreement. The law firm and the agency execute a written Reliance agreement that outlines the obligations and responsibilities of each party. InfoTrack provides a templated agreement within its Compliance Centre, which is executed digitally via DocuSign. Law firms that have developed their own agreement templates can also upload those directly into the system. There is no cost to either party to send or execute the agreement.
Completing the onboarding. Once the agreement is in place, the law firm proceeds with client onboarding as it would under its standard AML/CTF obligations. This includes the verification of identity (VOI), a KYC questionnaire, PEP and sanctions screening, and a client risk assessment. In cases where enhanced due diligence is required, such as verification of the source of funds, this is also completed at this stage.
Sharing the AML summary report. When the onboarding is complete, an AML summary report is made available to the agent through Securexchange, InfoTrack’s platform for real estate professionals. The system identifies the shared client automatically based on matching data points such as email address and phone number. No personal identifying information is shared directly. The report confirms that the required checks have been completed and provides the outcome, allowing the agent to accept the report and proceed to complete their own risk assessment, the remaining obligation that sits with the agency regardless of Reliance.

The technology manages the workflow between both parties. The lawyer does not need to manually select which reports to share or with which agent.

What the agent experience looks like

It is worth understanding the experience from the agent’s perspective, because the quality of that experience is central to the referral proposition.

Securexchange, the real estate-facing part of the InfoTrack platform, is where agents manage their AML obligations. When a shared client completes onboarding with the law firm, Securexchange notifies the agent that an AML report is available. The agent reviews the report, confirms acceptance, completes their own risk assessment and onboarding checks, and the client is onboarded on the agency side.

The entire experience is materially simpler than if the agent were conducting full AML onboarding independently. The checks they would otherwise need to complete have already been done. Their obligation is to review the report, assess the risk from their own perspective, and finalise their process. The client is not asked to provide documents or complete forms twice.

How to get started

The Reliance Agreements tab is live within the InfoTrack Compliance Centre. To initiate an agreement, a compliance officer selects the tab, enters the agency’s details, selects the InfoTrack Reliance template or uploads a custom agreement, sets the agreement term, and sends the DocuSign request to both parties for execution.

Firms that move now will be establishing these relationships before compliance requirements come into full effect. That head start compounds. The agencies that formalise their workflows with one firm before July are less likely to duplicate the exercise with multiple others.

To learn more about Reliance agreements and InfoTrack’s Compliance Centre, book a complimentary demonstration.

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