A house sale touches three Tranche 2 businesses: the agent, the conveyancer and, often, the accountant. Since 1 July each of them has had to verify the same buyer, and the buyer has photographed the same passport three times. Firms have asked us for a way around that since the day the obligations started. This is it.
What it is
CompliDesk Passport moves a verified client from one CompliDesk firm to another with a one-time code the client carries. The firm that did the check issues the code, with the client's consent. The client gives it to the new firm. The new firm types the code and the client's surname, and the file arrives.
It works for individuals, companies, trusts and partnerships. For a company or trust it brings the people under it as well.
What crosses
Everything on the file that the new firm would otherwise have to produce again:
- Identity details as verified: name, date of birth and address, and for an entity its ABN or ACN and its structure.
- The verification itself, carrying the original firm's date and method, not the date of the import. The new firm's file reads "Verified by [Firm A] on [date] via CompliDesk Passport", so the provenance is never in doubt.
- The questionnaire answers, the screening result and the risk rating as they stand. The new firm can change any of them; it does not have to start from nothing.
- A Certificate of Reliance, a PDF stored under the client that names both firms, the date and the method, and records the client's consent.
- For a company or trust, its extract or deed, copied into the new firm's folder, and each person under it with their own verification.
And what never crosses: the original firm's notes, its other documents, the ID images and any tax file number. Those stay where they were collected.
The rules that keep it honest
- One real check. A passport is issued only from a record the issuing firm verified itself. A record that arrived by passport cannot issue one, so there are no chains, and a record marked "verified elsewhere" cannot either.
- Under twelve months old. A verification older than that is refused and the new firm runs its own check.
- The code is single use and lasts 14 days. It can be cancelled while unused. The new firm must type the code and the client's surname; five wrong names lock the code, and a wrong code never reveals a name. Only a scrambled form of the code is ever stored.
- A company arrives with its structure identified, not verified. The new firm marks it verified once it is satisfied with the people under it, exactly as it would for any entity.
Does the law allow this?
In general terms, yes. The AML/CTF Act lets a reporting entity rely on customer due diligence that another reporting entity has carried out, provided the conditions in the Act and the Rules are met, and AUSTRAC publishes guidance on how that reliance is meant to work. What CompliDesk gives you is the record, the original firm's date and method, and a certificate stating what was relied on.
The decision to rely stays with you. The new firm remains the reporting entity for its own customer. Read the file, confirm it meets your program's standards, and talk to your adviser about whether a written reliance arrangement with the firms you regularly share clients with is right for you.
What it costs
The issuing firm pays nothing. The receiving firm pays one KYC credit for each record that arrives verified: every verified person is one credit and every company, trust or partnership is one credit. An individual is one credit; a company with two verified directors is three. A person who arrives unverified costs nothing until the new firm verifies them.
On a monthly plan the credits come from your allowance first, then any bonus credits, and a shortfall is paid at your plan's $3 a credit before the import runs. On pay as you go the import is paid up front at $12 a person and $20 an entity, the same prices as a single check.
How to do it
The firm that did the check
- Open the client and find Client passport under Step 1. Click Issue passport.
- Confirm the client has agreed to their details being shared with the new firm.
- Give the code to the client, or to the new firm with the client's agreement. It reads
CDP-XXXXX-XXXXXand lasts 14 days.
The firm receiving the client
- On the Clients page click Import with passport.
- Type the code and the client's surname, or the entity's name.
- Check the preview: who is arriving, who is verified and what it will cost. Confirm.
- The client appears in your list with Steps 1 to 4 showing what came across. Read it, change what you need to, and carry on as with any client.
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Related reading: KYC for companies and trusts · Customer due diligence explained · What is beneficial ownership? · KYC verification in CompliDesk