Beneficial ownership review checklist
Beneficial ownership verification is central to AML/CTF customer due diligence. Firms must identify the natural persons ultimately owning or controlling the client. This checklist is for AML compliance officers and client onboarding teams.
This is a 12-step checklist for verifying beneficial ownership of corporate, trust, and partnership clients under Australian AML/CTF rules.
The checklist
Obtain the organisational structure
Obtain a current structure chart showing all tiers of ownership.
Review ASIC extracts
Obtain ASIC extracts for each Australian company in the structure.
Identify the 25% threshold
Identify individuals directly or indirectly holding 25% or more of the client.
Identify controllers
Identify individuals exercising control through other means — voting rights, appointment, or veto.
Review trust deed
For trusts, obtain the trust deed and identify settlors, trustees, beneficiaries and appointors.
Identify discretionary beneficiaries
Document classes of discretionary beneficiaries and any default beneficiaries.
Review partnership agreements
For partnerships, obtain the partnership agreement identifying all partners.
Verify each identified person
Verify identity of each beneficial owner using reliable documents.
Check public registers
Check public beneficial ownership registers if available in relevant jurisdictions.
Document the chain
Document the full ownership chain and calculation of effective holdings.
Refresh annually
Refresh beneficial ownership information at defined intervals or on material change.
Retain records
Retain records for at least 7 years after the end of the relationship.
When this checklist applies
Use when onboarding any corporate, trust, or partnership client under AML/CTF rules.
Common pitfalls
- Missing control exercised through voting or appointment rights
- Discretionary trust beneficial owners not identified
- Structure chart missing international tiers
- Refresh schedule not tracked
- Records not retained for 7 years
Run this checklist on a real matter
Quillio can extract beneficial ownership from ASIC extracts and trust deeds. See /practice-areas/firm-management or start a free trial.
General guidance for beneficial ownership verification. Apply the current AML/CTF Rules and AUSTRAC guidance.
Use this checklist on your matter.
Quillio can run this checklist on a specific NSW conveyancing matter — confirm each item, calculate adjustments, and generate the supporting documents. The free trial requires no credit card.
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