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

Overview

There are two pathways planned, 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.

Please note: neither pathway is currently available in easyAML - both are coming soon. In the meantime, reliance can operate outside the platform under a written reliance agreement (for example by exporting and sharing the CDD evidence pack).

Pathway 1 - KYC done by another easyAML subscriber (coming soon)

For the same individual already verified by another easyAML firm, an in-platform Reliance/Sharing feature is coming soon: the originating firm will grant access to the verified data, the receiving firm will pull it across at a reduced fee, and a written reliance arrangement sits behind the relationship.

Pathway 2 - KYC done by an external provider (coming soon)

Please note: the ability to manually add an existing, previously-completed KYC/VOI from an external provider is not currently available in easyAML. This feature is coming soon. Once released, the KYC workflow will include 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 pathway will suit situations where 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, once the upload pathway is released easyAML will store the evidence for 7 years under AUSTRAC retention rules.

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