Skip to content
English - Australia
  • There are no suggestions because the search field is empty.

Does easyAML accept externally-provided VOI evidence (KYC done by another provider)?

Via the in-platform Reliance and Sharing feature when both firms use easyAML, or via the Upload Document path for evidence from an unrelated provider.

Overview

Yes - through two pathways, depending on whether the third party is another easyAML subscriber or an unrelated provider. Both rely on AUSTRAC's reliance framework (sections 37A and 38 of the AML/CTF Act), and in both the relying firm remains the reporting entity.

Pathway 1 - KYC done by another easyAML subscriber

For the same individual already verified by another easyAML firm, use the in-platform Reliance/Sharing feature: the originating firm grants access to the verified data, the receiving firm pulls it across at a reduced fee, and a written reliance arrangement sits behind the relationship. See the reliance section for the full workflow.

Pathway 2 - KYC done by an external provider

The KYC workflow includes an "Upload Document" option to attach external verification evidence instead of running a fresh VOI:

  • Create the KYC transaction and choose "Upload Document"
  • Attach the verification documents - the original VOI certificate, the ID document(s) sighted, signature evidence, and the PEP/sanctions/adverse-media result if completed externally
  • Mark the individual's verification status manually based on the external evidence

This is the right path when the customer was recently and rigorously verified by another regulated provider (a bank, another AML platform, a conveyancing search platform), a reliance arrangement is in place, or a fresh VOI would be duplicative - particularly for repeat clients.

What easyAML still does on its own

Regardless of what the external verifier did, easyAML re-runs PEP, sanctions and adverse-media screening on the relying firm's own infrastructure (a re-screen, not a duplicate - the lists change daily), stores the evidence for 7 years under AUSTRAC retention rules, and includes the record in ongoing monitoring at the normal re-screening cadence.

What the relying firm must still do (per AUSTRAC)

  • Have reasonable grounds to believe the external verification meets the reliable-and-independent-source standard. Vouchers from regulated entities (banks, certified financial institutions) generally pass; informal references usually don't.
  • Conduct your own risk assessment of the customer - reliance covers identity verification, not risk-based decisions.
  • Document the reliance - a written arrangement is preferred; case-by-case is acceptable but carries more liability.
  • Remain liable if the external verification turns out to be inadequate.

See AUSTRAC's Overview of reliance on customer identification by a third party (Reform).

Related articles