What does the agreement clause prohibiting "selling or sublicensing the Services" mean for a busines wanting to share CDD?
The clause stops commercial resale of easyAML's services to third parties; CDD reliance between parties to the same transaction is separately permitted.
The standard clause prohibits commercial resale or sublicensing of easyAML's services to third parties - i.e. a conveyancer can't repackage easyAML's CDD outputs as a paid service to other firms. That's not the same as CDD reliance between parties to the same transaction, which is genuinely permitted under AUSTRAC's framework and supported by the platform.
Reliance is permitted via a Special Condition added to the Service Agreement. This adds the specific authorisation for the firm to share verified CDD outputs with a defined counterparty (e.g. the agent on the other side of the conveyancing transaction) under a formal reliance agreement.
Backend support for the CDD reliance flow is being developed for 1 July 2026 - the operational mechanics for one firm to share a verified KYC/KYB with another via the platform, with appropriate consent, audit trail and notification. Once live, the reliance workflow becomes a button-click rather than a manual process.
In the meantime, firms wanting to operate reliance arrangements can do so by exporting the CDD evidence pack from easyAML and sharing it with the relying firm under their reliance agreement - workable today, becoming smoother once backend support lands. See AUSTRAC's Reliance reform for the regulatory framework.