Reliance
Reliance is the limited ability under MLR 2017 Regulation 39 to rely on CDD measures already carried out by another regulated person — such as another UK accountancy practice, law firm, or qualifying financial institution — rather than repeating them. Reliance requires written consent from the third party, immediate access to the underlying CDD records on request, and acceptance that legal responsibility for CDD remains with the relying firm.
reliance is most useful when taking on referred clients from another regulated firm. The relying firm still has to satisfy itself that the original CDD was adequate, document the reliance arrangement in writing, and update its own records — outsourcing the work does not outsource the liability.
How different roles use Reliance
A good definition should change the next action for the person reading it.
Partner or director
Check whether this term affects acceptance risk, fee scope, supervision exposure, or sign-off responsibility.
ContinueMLRO or compliance lead
Map the term to evidence, escalation, monitoring, training, and inspection readiness.
ContinueClient-facing team member
Use the plain-English explanation to ask better client questions and write clearer file notes.
ContinueOther terms that go with Reliance
Customer Due Diligence is the core legal obligation under MLR 2017 to identify clients, verify their identity using reliable independent sources, and understand the purpose and intended nature of the business relationship. Standard CDD applies to most clients. Where risk is elevated, Enhanced Due Diligence (EDD) is required instead.
A supervisory authority is the body responsible for overseeing AML compliance within a particular sector. For accountants not belonging to a professional body, the supervisory authority is HMRC. Members of recognised professional bodies (ICAEW, ACCA, CIMA, and others) are supervised by those bodies instead. For law firms in England and Wales, the supervisory authority is the Solicitors Regulation Authority (SRA), with parallel regulators in Scotland and Northern Ireland. Supervisory authorities set standards, conduct reviews, and can impose sanctions.
Before you treat Reliance as handled
- Confirm which regulation, policy, or internal procedure the term maps to.
- Document the decision or evidence trail in the client file, not only in email or chat.
- Escalate where the term indicates higher risk, sanctions exposure, PEP status, suspicion, or missing evidence.
- Keep the wording consistent across onboarding, review notes, training material, and inspection packs.
Put Reliance into practice with Certivus
Knowing the term is the first step. Certivus gives you the workflows — client intake, CDD, EDD, PEP and sanctions screening, audit-ready records — to apply it across every client.
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