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Australia's Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) Act was originally focused on financial institutions, banks, and remittance services (Tranche 1). Tranche 2 extends those obligations to professional services firms — including accountants, lawyers, and platform providers that create legal arrangements like trusts and companies.

As Smarter SMSF facilitates trust formations (SMSFs, LRBAs, discretionary trusts, unit trusts) and company incorporations directly through the platform, we are a reporting entity under the Act. This means we must verify the identity of firms and their clients before delivering these documents.

Only designated services are affected — these are documents that create new legal entities or transfer control of existing ones. Specifically: SMSF establishment, LRBA bare trusts, discretionary trusts, fixed unit trusts, change of trustee documents, LRBA loan facility agreements, and company incorporations performed on the platform.

All other documents — pension commencements, investment strategies, binding nominations, deed variations, trust deed updates, and general SMSF administration documents — are not affected. Business continues exactly as before for those.

A Reliance Agreement is a formal legal arrangement under Section 40 of the AML/CTF Act. It allows Smarter SMSF to formally rely on your firm's own AML/CTF program and KYC practices — meaning when you confirm you've verified a client, we can act on that confirmation without conducting our own separate verification.

You need a Reliance Agreement if your firm has its own AUSTRAC-registered AML/CTF program. This is typically accountancy and advisory firms registered with AUSTRAC as a reporting entity. If your firm doesn't have its own AML program, you follow the Full CDD path instead — no Reliance Agreement required.

The Compliance Hub is a dedicated section in your Smarter SMSF account where you manage your firm's AML/CTF obligations. It has three tabs: Firm Verification (one-time KYB and KYC of your principals), Reliance Agreement (sign and track your Section 40 agreement), and Client KYC History (a record of all verified clients).

Log in at sso.smartersmsf.com and go to the Admin Console to access the Compliance Hub. If you're an existing member and don't see it yet, we intend to have it available from 1 July 2026.

VerifiMe is an Australian digital identity platform purpose-built for AUSTRAC Tranche 2 compliance. It handles government database checks, biometric face matching, document validation, and PEP/sanctions screening — all in a single 2–5 minute experience that works on any device: phone, tablet, laptop, or desktop.

We chose VerifiMe because it's built specifically for the Australian professional services sector, it's approved under AUSTRAC standards, and it protects client privacy — we receive a verified attestation only, never raw identity documents or ID numbers. Clients also own their verified credentials in a reusable VerifiMe wallet, which they can share with any other Tranche 2 professional they work with — verify once, reuse everywhere.

No, if they were verified within the last 12 months. All verified client records are cached against your account for 12 months. When you place a new designated service order for the same client, the platform checks the record automatically — if it's still valid, the document releases immediately with no new verification required and no new fee.

If your client already has a VerifiMe wallet from any other professional, they can share their existing verified credentials with Smarter SMSF via a simple 2-click consent process — no re-verification required. They can also revoke access at any time via portal.verifime.com.

Your client will need at least one government-issued photo ID — typically an Australian passport, driver's licence, or Medicare card. VerifiMe supports thousands of document types from around the world, so overseas clients or those with international documents are also covered.

The verification process is guided step-by-step — your client takes a photo of their ID and a selfie for biometric matching. No scanning equipment or in-person visit is required. The whole process takes 2–5 minutes from any device.

Yes. VerifiMe guarantees Australian data sovereignty — all data is stored and processed within Australia. The platform uses AES-256 encryption for data at rest and TLS 1.3 for data in transmission, with isolated security zones separating data classifications.

Importantly, Smarter SMSF never receives your client's raw identity documents or ID numbers. We receive a verified attestation only — a confirmation that the check passed, along with a risk rating. Your client's actual documents remain secured within the VerifiMe platform, accessible only with the client's explicit consent.

Verification fees are charged per identity check and displayed at order checkout. Fees only apply when a new VerifiMe verification is triggered — Smarter SMSF will capture this as part of the document order fee. No fee applies for repeat clients within 12 months, and not for firm-level verification (KYB/KYC of your principals, which Smarter SMSF covers). You can on-charge these fees to your client as a disbursement if appropriate for your practice.

If VerifiMe returns a HIGH risk assessment, the order is placed on hold and our compliance team is notified immediately. A Smarter SMSF compliance team member will review the assessment, contact you within 1 business day, and advise on next steps — which may include requesting additional documentation or, in rare cases, declining the order.

LOW or MEDIUM risk results in automatic document release. FAILED results (verification could not be completed) will prompt us to notify you so you can assist your client in retrying.

AML/CTF compliance is managed at the firm level by the Subscription Owner. Team members added through the Admin Console inherit the owner's AML status automatically — they do not need to complete separate compliance steps.

When a team member places a designated service order, the platform applies the firm's AML pathway (Reliance or Full CDD) automatically. The team member simply places the order as normal — the compliance logic runs in the background.

Yes — all non-designated service documents remain fully accessible regardless of your AML/CTF status. Pension documents, investment strategies, deed variations, binding nominations, and most standard SMSF documents are not affected and will continue to work exactly as before.

If firm verification is not yet complete, designated service orders (SMSF establishments, trust formations, company incorporations, LRBA documents) will be subject to standard CDD requirements through VerifiMe. You'll see a clear message in the Compliance Hub guiding you through what's needed.

Under the AML/CTF Act, we are required to retain CDD records for 7 years from the date of the last transaction. We store all verification records securely and in accordance with our Privacy Policy. We never store raw identity documents — VerifiMe holds those within their secure platform and provides us with a verified outcome only.

You can view all client verification records at any time in the Client KYC History tab of your Compliance Hub.