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Requesting beneficial ownership information from a corporate client

A practical approach to asking about ultimate ownership and control.

Understanding who ultimately owns or controls a corporate client is a core part of customer due diligence, but the question can feel unusual to clients who aren't used to being asked. This guide sets out a practical approach to asking it clearly. It is general information, not legal or compliance advice.

Action plan

1 Explain why the question is being asked A short explanation that this is standard practice for corporate clients generally reduces friction.

Customer due diligence for a corporate client generally extends beyond the people named on the public register to the individuals who ultimately own or control it. Framing the question as a standard part of onboarding every corporate client, rather than something specific to them, generally helps the conversation go smoothly.

  • Explain that beneficial ownership questions are asked of every corporate client
  • Ask who ultimately owns or controls the company, not just who is listed as a director
  • Give the client a plain description of what "beneficial owner" means in this context

Done when: The client has been asked clearly who ultimately owns or controls the business

AUSTRAC: overview of customer due diligence
2 Ask about ownership and control separately Ownership and control aren't always held by the same person; ask about both.

A person can control a company without owning a large share of it (for example, through voting arrangements or a senior management role), and an owner may not be involved in day-to-day control. Ask about both ownership and control so the picture is complete.

  • Ask who owns significant shares or interests in the company
  • Ask who controls the company's decisions, even if they hold no shares
  • Document both separately rather than assuming they're the same people

Done when: Both ownership and control have been documented, even if held by different people

AUSTRAC: overview of customer due diligence
3 Verify against independent evidence where practical Cross-check what the client tells you against independent evidence where you can.

Where practical, cross-check what the client tells you about beneficial ownership against independent evidence, such as company register information or supporting documents, rather than relying on the client's statement alone.

  • Cross-check stated beneficial owners against available independent evidence
  • Note where independent evidence isn't available and why
  • Escalate through your firm's process if the client's account doesn't add up

Done when: Stated beneficial ownership has been checked against independent evidence where practical

See requesting formation documents from a new company client