Reliance Membership: how it works (Pathway A)

Audience: Firms with their own AUSTRAC AML/CTF program

Pathway A is designed for accounting and advisory firms that are already registered with AUSTRAC as reporting entities and maintain their own AML/CTF program. If this is your firm, the Reliance Membership is the most efficient path — it means your clients don't need to complete any identity verification at the point of ordering.

Am I eligible for Pathway A?

You are eligible if your firm:

• Is registered with AUSTRAC as a reporting entity

• Maintains a compliant AML/CTF program (Part A risk assessment + Part B CDD procedures)

• Can demonstrate that your KYC procedures meet the standard required under the AML/CTF Act

If you're unsure whether your firm qualifies, contact your compliance adviser or check your AUSTRAC registration.

Step 1 — One-time firm verification

Before designated services are unlocked, your firm completes a one-time verification through the Compliance Hub in your account:

• KYB (Know Your Business): Your entity is checked against the ASIC register and ABN records, and screened for PEP and sanctions exposure.

• KYC (Know Your Customer): Each director and beneficial owner holding 25% or more completes a VerifiMe digital identity check — 2–5 minutes on any device, using photo ID plus biometric selfie match.

This step is completed once. You will not need to repeat it unless your firm's structure or principals change.

Step 2 — Signing the Reliance Agreement

Once verification is complete, you sign a Reliance Agreement with Smarter SMSF under s.37A of the AML/CTF Act. This is a formal legal agreement confirming that Smarter SMSF can rely on your firm's own compliance and KYC practices for each designated service order.

The agreement is executed electronically via BoxSign and held on your account record.

Step 3 — Per-order attestation

When you place a designated service order, you confirm via a simple attestation that you have completed your own client due diligence in accordance with your AML/CTF program. The document is then released immediately — your client does not need to take any action.

The attestation requires you to confirm three things:

• KYC Procedures have been completed for all Relevant Persons associated with the order
• There is no known or suspected money laundering, terrorism financing, or other criminal activity in relation to any Relevant Person
• The KYC Procedures were not satisfied solely by reliance on a continuing client concession — full Initial CDD has been separately completed for each Relevant Person in connection with the designated       service.

Important — continuing client concession: If your firm applies the continuing client concession under the AML/CTF Rules for an existing client, this does not satisfy the attestation requirement. The concession belongs to your firm, not to Smarter SMSF. Where a concession has been applied, you must confirm that full KYC has been separately completed for that client in connection with this specific designated service order. If you cannot confirm this, contact our compliance team before placing the order — Smarter SMSF will need to complete its own CDD for that client.

Ongoing obligations

Under s.37B of the AML/CTF Act, Smarter SMSF may conduct annual assessments of all Reliance Agreements. We will contact you at least 60 days before any review with details of what's required. In most cases this will be a straightforward written confirmation that your program remains compliant.

How to get started

Log in to your account and navigate to Admin Console → AML Compliance Hub. The guided setup takes approximately 15 minutes.