What is reliance?
Reliance means using another regulated firm’s customer due diligence on a shared client instead of doing the checks again yourself. Under regulation 39 of the Money Laundering Regulations 2017 (MLRs), it is allowed only with the other firm’s agreement and immediate access to the information. Your firm stays liable for any failure in those checks.
A common example is an estate agent relying on the buyer’s conveyancer, or one accountancy practice relying on another that already acts for the client.
The UK rules
| Rule | What it says | Where |
|---|---|---|
| What you can rely on | Another firm’s identification and verification of the client and beneficial owner, and the purpose of the relationship (reg 28(2)–(6) and (10)), and its reg 30A register checks | Reg 39(1) |
| Liability | You “remain liable for any failure to apply such measures” | Reg 39(1) |
| Get the information | Immediately obtain from the third party all the information needed to identify the client, any beneficial owner and anyone acting for the client | Reg 39(2)(a) |
| Arrangements | Have arrangements in place so the third party gives you copies of the identification and verification data immediately on request, and keeps the records for the reg 40 period | Reg 39(2)(b) |
| Who qualifies | Another firm regulated under the MLRs, or certain overseas firms subject to equivalent CDD and record-keeping rules and supervision | Reg 39(3) |
| Who doesn’t | A third party established in a FATF call for action country (with limited group exceptions) | Reg 39(4)–(5) |
| Outsourcing is different | Using an agent or outsourcing provider to carry out CDD for you is allowed if you remain liable, but it is not reliance | Reg 39(7)–(8) |
Source: MLR regulation 39, as amended by SI 2026/621 from 30 June 2026; regulation 40.
What reliance does not cover
- Ongoing monitoring. Reg 39(1) covers the initial CDD measures, not your duty to monitor the relationship under reg 28(11). That stays with you.
- Your risk assessment. You still need to decide the risk for your own client and work, and apply enhanced due diligence if needed.
- Your liability. If the other firm’s checks were inadequate, your firm is still responsible.
What this means for estate agents and conveyancers
- Ask, don’t assume. The conveyancer has to agree to be relied on and to provide copies immediately when asked. Some firms decline. If they agree, put it in writing.
- Get the information at the start, not just a confirmation that checks were done.
- Consider doing your own check. Since the estate agent has a business relationship with the buyer from the point the offer is accepted (reg 4(3)), running your own client check can be simpler than setting up reliance.
See our guides to AML for estate agents and who pays for AML checks when buying a house.
Frequently asked questions
Can an estate agent rely on the buyer’s solicitor’s AML checks?
Yes, if the solicitor agrees, you obtain the CDD information immediately, and you have arrangements to get copies of the documents on request. You remain liable if those checks fall short, and ongoing monitoring stays with you.
Is an ID verification provider a third party I can rely on under reg 39?
Generally no. A technology provider that runs checks for you is a tool or an outsourced service, not a regulated firm that has done its own CDD on the client. You are applying CDD yourself, and you stay responsible for it.
Does reliance move liability to the other firm?
No. Reg 39(1) says the relying firm remains liable for any failure to apply the measures.
How AML Buddy helps
If you would rather not rely on another firm, AML Buddy lets you run your own check: your client verifies their ID document and selfie through one secure link, and you get address, sanctions, PEP and adverse media results in a timestamped PDF report. £5.40 per check inc. VAT, no subscription. See pricing.