Client verification Current
Verifying beneficial ownership evidence for a company or trust client
A practical approach to checking, not just recording, ownership evidence.
Asking who beneficially owns or controls a client is only half the task; checking the answer against independent evidence is the other half. This guide sets out a practical approach. It is general information, not legal or compliance advice.
Action plan
1 Compare the client's answer against independent evidence Where practical, check stated beneficial owners against evidence that doesn't come from the client alone.
Where practical, cross-check what the client tells you about beneficial ownership against independent evidence, such as company register information, shareholder registers, or trust deed provisions, rather than relying on the client's statement alone.
- Cross-check stated beneficial owners against the public company register where relevant
- Cross-check against the trust deed or shareholder register where relevant
- Note where independent evidence isn't available and why
Done when: Stated beneficial ownership has been checked against available independent evidence
AUSTRAC: overview of customer due diligence2 Look through layered ownership structures Where a company or trust owns another entity, follow the chain to the individuals at the top.
Ownership structures aren't always a single layer. Where a company or trust is itself owned by another company or trust, the verification task is to follow that chain until you reach the individuals who ultimately own or control it.
- Ask whether any owner in the structure is itself a company or trust, not an individual
- Follow the ownership chain until you reach the individuals at the top
- Document each layer of the structure as you verify it
Done when: The full ownership chain has been documented down to the individuals who ultimately own or control it
See requesting beneficial ownership information from a corporate client