What does NOT get you to deemed compliance
A single unanswered email, no attempted reliance via the conveyancer, no documentation, no SMR consideration, or ignoring red flags will all defeat the deemed compliance provision.
Deemed compliance requires sufficient effort that has been unsuccessful, examples that are not likely to meet the standard are: A single unanswered email (insufficient effort) No attempt at reliance via the conveyancer (a reasonable step skipped) No documentation of the attempts (no audit trail) No SMR consideration recorded (third criterion not met) Ignoring red flags — if reasonable suspicion exists, an SMR is mandatory, and proceeding without one is itself a contravention If any of these is missing, you're back under the general rule: where you can't establish the required matters on reasonable grounds, you must not start providing the designated service, and an SMR must be lodged if you reasonably suspect the customer isn't who they claim to be (AUSTRAC explicitly links the "cannot establish on reasonable grounds" outcome to both a stop on service provision and a mandatory SMR where identity doubt is the cause).
For the full answer, see What are the critical limits on using Deemed Compliance provision?.
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