AML/CTF compliance for document subscription team members

Audience: Account owners and team members on team plans

If your Smarter SMSF subscription includes multiple team members, AML/CTF compliance is managed at the firm level — not at the individual user level. This means the account owner completes the compliance setup once, and all team members benefit from it automatically.

Account owner responsibilities

The account owner is responsible for:

●        Determining which pathway applies to your firm (Pathway A — Reliance Membership, or Pathway B — Full CDD via VerifiMe)

●        Completing firm verification if on Pathway A (KYB + KYC for principals)

●        Signing the Reliance Agreement if on Pathway A

●        Ensuring the firm's AML/CTF status is kept up to date if principals change

Team member experience

Team members do not need to complete any separate AML/CTF verification. When a team member places a designated service order:

●        Pathway A: A per-order attestation is presented to the team member to confirm they have completed client due diligence under the firm's AML/CTF program.

●        Pathway B: The client verification flow is triggered automatically — a VerifiMe invite is sent to the client, and the document is released once verification is complete.

How to check your firm's AML/CTF status

Account owners can view the firm's current compliance status at any time by navigating to Admin Console → Compliance Hub.

What if a principal changes?

If a director, beneficial owner, or key signatory on your account changes, you must notify Smarter SMSF. The new principal will need to complete a VerifiMe identity check before designated services can continue to be accessed under Pathway A.

To notify us of a change, log a ticket with our compliance team →

PAYG (individual) members

If you are a PAYG member (not on a team plan), the same pathways apply — the distinction is that you are both the account owner and the sole user. Compliance setup is completed under your individual account.

Smarter SMSF is a reporting entity under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth). These articles provide general information only and do not constitute legal or compliance advice.

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