Rely on third parties —
with the registry the Act demands
Sections 37 and 38 let you rely on another reporting entity's CDD work, but only if you can show you maintain the relationship properly. duely's reliance partner registry tracks every arrangement: who, what scope, what agreement, when it was last reviewed, and when it expires.
Why this matters
Reliance is genuinely useful — your firm doesn't need to re-verify a customer your bank has already KYC'd, provided the legal conditions are met. But the conditions in s37 and s38 carry teeth: you have to maintain the arrangement, periodically review the partner, and demonstrate the agreement on demand.
duely's reliance system is a full registry. Every partner has a record with their entity details, the scope of reliance, the underlying agreement, the periodic review schedule, and the expiry tracking. When a review or expiry comes up, the calendar surfaces it. When an evidence pack is generated for a matter that used reliance, the partner reference goes with it.
What is included now
Reliance partner registry
Central record per partner with entity details, scope of reliance, contact data, and the matters that depend on the arrangement.
s37 vs s38 distinction
The system tracks which section your reliance falls under — s37 (one-off reliance on another reporting entity) versus s38 (ongoing reliance under a written arrangement) — so the right conditions are applied to each partner.
Agreement PDF generation
Generate the underlying reliance agreement document directly from the registry data. Keeps the paperwork consistent and tied to the partner record rather than a Word file in a shared drive.
Periodic review automation
The RelianceReview scheduled job watches review dates daily and surfaces them on the compliance calendar with escalating reminders. Periodic review never silently slips.
Agreement expiry tracking
The RelianceAgreementExpiry job flags agreements approaching renewal so reliance never silently lapses between agreement versions.
Matter-level reliance linkage
When a matter relies on a partner's CDD, the partner reference is captured on the matter and flows through into the evidence pack so the reliance is defensible later.
Drift propagation to bound matters
Partner status changes feed the customer-baseline drift detection, so changes in a reliance partner propagate to every matter that uses them — Apply, Rebind, or Upgrade with rationale.
AML/CTF Act sections 37 & 38
- s37 — reliance on another reporting entity's CDD (one-off basis)
- s38 — reliance under a written arrangement (ongoing basis)
- Reporting entity remains responsible for the reliance work
- Periodic review of the reliance partner is required
- Written agreement required for s38 arrangements; must be available on demand
Related features
See how this capability connects to the broader compliance workflow.
Matter Workflow
Matters reference reliance partners; the partner reference flows into evidence packs.
Learn more →AML/CTF Program
Your program documents the firm's approach to third-party reliance.
Learn more →Compliance Calendar
Reliance review and agreement expiry deadlines are watched by scheduled jobs.
Learn more →Reliance you can defend in audit
Registry, agreements, reviews, and expiries — all in one place.