Client intake Current
Requesting formation documents from a new company client
A practical checklist for onboarding a company client.
Onboarding a company client generally means confirming the company is genuinely registered, understanding its structure, and identifying the people who control it. This guide sets out a practical approach. It is general information, not legal or compliance advice.
Action plan
1 Confirm the company is registered Check the company appears on the official companies register before relying on anything it provides.
In Australia, companies are registered on the companies register administered by ASIC. A genuinely registered company will have an Australian Company Number (ACN) and a certificate of registration. Confirming these against the public register is a useful first check before treating any other document as reliable.
- Ask the client for the company's ACN
- Confirm the company's registration status against the public companies register
- Note any mismatch between what the client states and what the register shows
Done when: The company's ACN and registration status have been confirmed against the public register
ASIC: search ASIC registers2 Request the company's formation documents Ask for the certificate of registration and the company's constitution, if it has one.
A company's certificate of registration confirms when and how it was formed. Not every company has a separate written constitution; some rely on the standard replaceable rules. Ask which applies and request whichever document is relevant, along with the register of officeholders and members.
- Request the certificate of registration
- Ask whether the company has its own constitution or relies on the replaceable rules, and request whichever applies
- Request the register of officeholders and the register of members
Done when: Formation documents and officeholder/member registers have been requested and received
ASIC: register a company3 Identify who ultimately controls the company Understand who the company's beneficial owners are, not just its registered officeholders.
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 the company. Ask the client directly who these individuals are, and be ready to verify their identity separately using the same approach as for an individual client.
- Ask who ultimately owns or controls the company, not just who is listed as a director
- Treat each identified beneficial owner as needing their own identity verification
- Document the ownership and control structure you were told, so it can be reviewed later
Done when: The company's beneficial owners have been identified and documented
AUSTRAC: overview of customer due diligence