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Ready reckoner

Summary of AML/CTF program requirements relating to identification and verification of customers and beneficial owners

Under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (AML/CTF Act) reporting entities offering one or more designated services must identify and verify their customers.

The AML/CTF Act requires reporting entities to check a customer's identity before providing a designated service to the customer. Only in special circumstances specified in the AML/CTF Rules can a reporting entity delay checking a customer's identity until after a designated service has been provided.

The AML/CTF Rules set out the minimum customer identification information, and information about beneficial owners of a customer, which reporting entities must collect and verify. Reporting entities are also required to identify whether a customer or the beneficial owner of a customer is a 'politically exposed person' (PEP).

The AML/CTF Rules require verification of customer information from reliable and independent documentation or electronic data, or a combination of both.

Further information on AML/CTF programs and the obligations of reporting entities is available in the AUSTRAC compliance guide.

This ready reckoner outlines the minimum identification information reporting entities must collect and verify for the following customer types:


Individual customer

Other than a sole trader

For more information see Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) Rules: 4.2.3 and 4.2.6

Name

  • Collect and verify the full name of the individual.  A customer’s full name comprises all of the customer’s given names and their family name.

‘Safe harbour’ verification procedures for individual customers 

  • Where the relationship with the customer is of medium or lower ML/TF risk, the reporting entity may elect to use the safe harbour verification procedures in paragraphs 4.2.10 – 4.2.13 of the AML/CTF Rules, which do not require verification of the customer’s full name.

Address and date of birth

  • Collect the residential address
  • Collect the date of birth
  • Verify either the residential address or date of birth

PEPs

  • Determine whether the individual is a PEP

Beneficial owner(s)

  • For individuals, a reporting entity may assume that the customer and beneficial owner are the same person, unless there are reasonable grounds to consider otherwise.

VERIFY: See AML/CTF Rules 4.2.7, 4.2.10-4.2.13 for more information on how to verify.


Individual customer

Acting as a sole trader

For more information see AML/CTF Rules: 4.2.4 and 4.2.6

Name

  • Collect and verify the full name of the individual. A customer’s full name comprises all of the customer’s given names and their family name.

‘Safe harbour’ verification procedures for individual customers 

  • Where the relationship with the customer is of medium or lower ML/TF risk, the reporting entity may elect to use the safe harbour verification procedures  in paragraphs 4.2.10 – 4.2.13 of the AML/CTF Rules, which do not require verification of the customer’s full name.

Address and date of birth

  • Collect either the residential address or full address of the customer's principal place of business (if any)
  • Collect the date of birth
  • Verify either the residential address or the date of birth

Other

  • Collect the full business name under which the customer carries on their business (if any)
  • Collect the Australian Business Number (ABN) issued to the customer (if any)

PEPs

  • Determine whether the individual is a PEP

Beneficial owner(s)

  • For individuals, a reporting entity may assume that the customer and beneficial owner are the same person, unless there are reasonable grounds to consider otherwise

VERIFY: See AML/CTF Rules 4.2.7, 4.2.10-4.2.13 for more information on how to verify.


Company

Domestic

For more information see AML/CTF Rules: 4.3.2, 4.3.3(1), 4.3.5(1), 4.3.8

Name

  • Collect and verify the full name of the company, as registered by the Australian Securities and Investments Commission (ASIC)

Address

  • Collect the full address of the company's registered office
  • Collect the full address of the company's principal place of business (if any)

Other

  • Collect and verify the Australian Company Number (ACN) issued to the company
  • Collect and verify whether the company is registered by ASIC as a proprietary or public company
  • Collect the name of each director if the company is a proprietary company

Beneficial owner(s)

  • Identify the beneficial owner(s) of the company
  • Determine whether each beneficial owner of the company is a PEP

Simplified company verification procedure

Confirm that the company is either:

  • a domestic listed public company
  • a majority owned subsidiary of a domestic listed public company
  • licensed and subject to Commonwealth, state or territory regulatory oversight in relation to its activities as a company.

Identification and verification of the beneficial owner(s) is not required for a company which has been verified under the 'simplified company verification procedure'.

VERIFY: See AML/CTF Rules 4.3.10-4.3.11, 4.9.4-4.10.2 for more information on how to verify.

Disclosure certificates can be used for verification purposes in certain circumstances. See AML/CTF Rules 30.2 and 30.3 for more information on using disclosure certificates for domestic companies.

CONFIRM: For more information on how to confirm the status of these types of companies see Rule 4.3.8.


Company

Registered foreign

For more information see AML/CTF Rules: 4.3.2, 4.3.3(2), 4.3.5(2)

Name

  • Collect and verify the full name of the company, as registered by ASIC

Address

  • Collect the full address of the company's Australian registered office

Collect one of the following:

  • Full address of the company's principal place of business in Australia (if any)
  • Full name and address of the company's local Australian agent (if any)

Other

  • Collect and verify the Australian Registered Body Number (ARBN) issued to the company
  • Collect the name of the country in which the company was formed, incorporated or registered
  • Collect and verify whether the company is registered by the relevant foreign registration body, and if so, whether it is registered as a private, public or other type of company
  • Collect the name of each director if the company is registered as a private company

Beneficial owner(s)

  • Identify the beneficial owner(s) of the company
  • Determine whether each beneficial owner of the company is a PEP
  • Identification and verification of the beneficial owner(s) is not required for a foreign listed public company which is subject to 'transparency of beneficial owner' disclosure requirements (whether by stock exchange rules or by law or enforceable means) which are, or are comparable to, the requirements in Australia

VERIFY: See AML/CTF Rules 4.3.9, 4.3.10-4.3.11, 4.9.4-4.10.2 for more information on how to verify. Disclosure certificates can be used for verification purposes in certain circumstances. See AML/CTF Rules 30.2 and 30.4 for more information on using disclosure certificates for foreign companies registered in Australia.


Company

Unregistered foreign (registered by relevant foreign registration body)

For more information see AML/CTF Rules: 4.3.2, 4.3.3(3), 4.3.5(3)

Name

  • Collect and verify the full name of the company

Address

  • Collect the full address of the company in the country of formation, incorporation or registration

Other

  • Collect the name of the country in which the company was formed, incorporated or registered
  • Collect and verify any identification number issued to the company
  • Collect and verify whether the company is registered as a private, public or other type of company
  • Collect the name of each director if the company is registered as a private company

Beneficial owner(s)

  • Identify the beneficial owner(s) of the company
  • Determine whether each beneficial owner of the company is a PEP
  • Identification and verification of the beneficial owner(s) is not required for a foreign listed public company which is subject to 'transparency of beneficial owner' disclosure requirements (whether by stock exchange rules or by law or enforceable means) which are, or are comparable to, the requirements in Australia

VERIFY: See AML/CTF Rules 4.3.9, 4.3.10-4.3.11, 4.9.4-4.10.2 for more information on how to verify. Disclosure certificates can be used for verification purposes in certain circumstances. See AML/CTF Rules 30.2 and 30.5 for more information on using disclosure certificates for foreign companies not registered in Australia.


Company

Unregistered foreign (not registered by relevant foreign registration body)

For more information see AML/CTF Rules: 4.3.2, 4.3.3(3), 4.3.5(3)

Name

  • Collect and verify the full name of the company

Address

  • Collect the full address of the principal place of business of the company in the country of formation or incorporation

Other

  • Collect the country in which the company was formed or incorporated

Beneficial owner(s)

  • Identify the beneficial owner(s) of the company
  • Determine whether each beneficial owner of the company is a PEP
  • Identification and verification of the beneficial owner(s) is not required for a foreign listed public company which is subject to 'transparency of beneficial owner' disclosure requirements (whether by stock exchange rules or by law or enforceable means) which are, or are comparable to, the requirements in Australia

VERIFY: See AML/CTF Rules 4.3.10-4.3.11, 4.9.4-4.10.2 for more information on how to verify.

Disclosure certificates can be used for verification purposes in certain circumstances. See AML/CTF Rules 30.2 and 30.5 for more information on using disclosure certificates for foreign companies not registered in Australia.


Partnership

For more information see AML/CTF Rules: 4.5.2, 4.5.3, 4.5.5

Name

  • Collect and verify the full name of the partnership (see AML/CTF Rule 4.5.5(1) for more detail on how to verify)
  • Collect the full business name as registered with any state or territory business name authority
  • Collect the full name of each partner (not required if the regulated status of the partnership is confirmed by referring to a current membership directory of the relevant professional association)

Address

  • Collect the full residential address of each partner (not required if the regulated status of the partnership is confirmed by referring to a current membership directory of the relevant professional association)

Other

  • Collect the name of the country in which the partnership was established
  • Collect and verify the information relating to one of the partners (as per the 'Individual' identification procedure)

Beneficial owner(s)

  • Identify the beneficial owner(s) of each partner
  • Determine whether each of the partners or the beneficial owner of each partner is a PEP

VERIFY: See AML/CTF Rules 4.5.7-4.5.8, 4.9.4-4.10.2 for more information on how to verify.

Disclosure certificates can be used for verification purposes in certain circumstances. See AML/CTF Rules 30.2 and 30.7 for more information on using disclosure certificates for partnerships.


Trustee

For more information see AML/CTF Rules: 4.4.2, 4.4.3, 4.4.5, 4.4.8, 4.4.9

Name

  • Collect and verify the full name of the trust (see AML/CTF Rule 4.4.5(1) for more detail on how to verify)
  • Collect the full business name (if any) of the trustee of the trust
  • Collect the full name of all trustees
  • Collect and verify the settlor of the trust, unless:
    • the material asset contribution to the trust by the settlor at the time the trust is established is less than $10,000; or
    • the settlor is deceased; or
    • the trust is verified using the simplified trustee verification procedure

Address

  • Collect the full address of all trustees

Other

  • Collect information regarding the type of trust and the country in which the trust was established

Beneficiaries

Collect one of the following:

  • full name of each beneficiary of the trust (see AML/CTF Rules 4.4.11-4.4.12 for more information about verification)
  • if beneficiaries are identified by reference to a class, details of the class (see AML/CTF Rules 4.4.11-4.4.12 for more information about verification)

Sole trustee

  • Collect and verify information relating to the sole trustee (as per appropriate 'Individual' or 'Company' identification procedure)

Multiple trustees

  • Collect and verify information relating to one trustee (as per appropriate 'Individual' or 'Company' identification procedure)

Beneficial owner(s)

  • Determine the beneficial owner(s) of the trust
  • Collect and take reasonable measures to verify each beneficial owner’s full name and one of either the beneficial owner’s date of birth or full residential address
  • Determine whether a beneficial owner of the trust is a PEP

VERIFY: See AML/CTF Rules 4.4.15–4.4.16 and 4.9.4–4.10.2 for more information on how to verify.

Disclosure certificates can be used for verification purposes in certain circumstances. See AML/CTF Rules 30.2 and 30.6 for more information on using disclosure certificates for trusts.

Simplified trustee verification procedure

Verify that the trust is either:

  • a managed investment scheme registered by ASIC
  • a managed investment scheme not registered by ASIC that only has wholesale clients and does not make small scale offerings to which section 1012E of the Corporations Act 2001 applies
  • registered and subject to Commonwealth regulatory oversight in relation to its trust activities
  • a government superannuation fund established by legislation

Identification and verification of the beneficial owner(s) is not required for a trust which has been verified under the 'simplified trustee verification procedure' .

VERIFY: For more information on how to verify the status of these types of trusts, see AML/CTF Rule 4.4.8.


Association

Incorporated association

For more information see AML/CTF Rules: 4.6.2, 4.6.3(1), 4.6.5

Name

  • Collect and verify the full name of the association
  • Collect the full name of the chairman, secretary and treasurer or equivalent officer (in each case)

Address

Collect one of the following:

  • Full address of the principal place of administration or registered office (if any) (only one of these required for collection)
  • Residential address of the public officer
  • Residential address of the president, secretary or treasurer (if no public officer) (only one of these required for collection)

Other

  • Collect and verify any unique identifying number issued to the association by the incorporating state, territory or overseas 'incorporation body'

Beneficial owner(s)

  • Identify the beneficial owner(s) of the association
  • Determine whether each beneficial owner of the association is a PEP

VERIFY: See AML/CTF Rules 4.6.5(1), 4.6.7-4.6.8, 4.9.4-4.10.2 for more information on how to verify. Disclosure certificates can be used for verification purposes in certain circumstances. See AML/CTF Rule 30.2 and 30.8 for more information on using disclosure certificates for incorporated associations.


Association

Unincorporated association

For more information see AML/CTF Rules: 4.6.2, 4.6.3(2), 4.6.5

Name

  • Collect and verify the full name of the association
  • Collect the full name of the chairman, secretary and treasurer or equivalent officer (in each case)

Address

  • Collect the full address of the principal place of administration (if any)

Other

  • Collect and verify information relating to the member (as per the appropriate 'Individual' identification procedure where the customer is acting in the capacity of a member of the unincorporated association

Beneficial owner(s)

  • Identify the beneficial owner(s) of the association
  • Determine whether each beneficial owner of the association is a PEP

VERIFY: See AML/CTF Rules 4.6.5(2), 4.6.7-4.6.8, 4.9.4-4.10.2 for more information on how to verify. Disclosure certificates can be used for verification purposes in certain circumstances. See AML/CTF Rules 30.2 and 30.8 for more information on using disclosure certificates for unincorporated associations.


Registered co-operative

For more information see AML/CTF Rules: 4.7.2, 4.7.3, 4.7.5

Name

  • Collect and verify the full name of the co-operative
  • Collect the full name of the chairman, secretary and treasurer or equivalent officer (in each case)

Address

Collect only one of the following:

  • Full address of the registered office
  • Principal place of operations (if any)
  • Residential address of the co-operative's secretary
  • Residential address of the co-operative's president or treasurer (if no secretary)

Other

  • Collect and verify any unique identifying number issued to the co-operative on registration by the state, territory or overseas 'registration body'

Beneficial owner(s)

  • Identify the beneficial owner(s) of the registered co-operative
  • Determine whether each beneficial owner of the registered co-operative is a PEP

VERIFY: See AML/CTF Rules 4.7.5, 4.7.7-4.7.8, 4.9.4-4.10.2 for more information on how to verify.

Disclosure certificates can be used for verification purposes in certain circumstances. See AML/CTF Rule 30.2 and 30.9 for more information on using disclosure certificates for registered co-operatives.


Government body

For more information see AML/CTF Rules: 4.8.2, 4.8.3, 4.8.5

Name

  • Collect and verify the full name of the government body

Address

  • Collect and verify the full address of the government body's principal place of operations

Other

  • Collect and verify whether the government body is:
    • a separate legal entity, agency or authority; and/or
    • established under legislation of the Commonwealth, state or territory or a foreign country; and if so the name of the state, territory or foreign country

Beneficial owner(s)

  • Identification and verification of the beneficial owner(s) is not required for an Australian Government entity.
  • Optional procedure - collect and verify the beneficial owner(s) of a foreign government body (AML/CTF Rules 4.8.7-4.8.8 provide more detail about collecting and verifying information about the beneficial owner(s) of foreign government bodies)
  • Determine whether each beneficial owner of the foreign government body is a PEP

VERIFY: See AML/CTF Rules 4.8.5, 4.9.4-4.10.2 for more information on how to verify


Agent

Of an individual customer

For more information see AML/CTF Rules: 4.11.1, 4.11.2

Name

  • Collect the full name of each agent acting on the customer's behalf regarding the provision of the designated service(s)

Other

  • Collect evidence (if any) of the authorisation of the agent to act on behalf of the customer

VERIFY: See AML/CTF Rules 4.11.3-4.11.4 for more information on how to verify.


Agent

Of a non-individual customer

For more information see AML/CTF Rules: 4.11.5, 4.11.6

Name

  • Collect the full name of each agent acting on the customer's behalf regarding the provision of the designated service(s)

Other

  • Collect evidence of the authorisation of the agent to act on behalf of the customer

VERIFY: See AML/CTF Rules 4.11.7-4.11.8 for more information on how to verify.


Verifying officer

Appointed by a non-individual customer to verify their agent(s) only

For more information see AML/CTF Rules: 4.11.9, 4.11.12

Name

  • Collect the full name of the agent(s)

Other

  • Collect the title of the position/role held by the agent(s) with the customer
  • Collect a copy of the signature of the agent(s)
  • Collect evidence of the authorisation of the verifying officer to act on behalf of the customer
  • Collect and verify information relating to the verifying officer (as per the appropriate 'Individual' identification procedure)

Beneficial owner(s) of customers

Where the identity of the beneficial owner(s) is known

For more information see AML/CTF Rules: 4.12.1, 4.12.2 and 4.12.4-4.12.7

Name

Address and date of birth

  • Collect and verify one of the following:
    • residential address of each beneficial owner
    • date of birth of each beneficial owner

PEPs

  • Determine whether any of the beneficial owners of the customer is a PEP

VERIFY: Reasonable measures must be taken to verify beneficial owners. See AML/CTF Rules 4.12.4-4.12.7 for more information on how to verify.

Disclosure certificates can be used for verification purposes in certain circumstances. See Chapter 30 of the AML/CTF Rules for further information.

Where the identity of the beneficial owner(s) is unable to be determined, see AML/CTF Rule 4.12.9 and Chapter 6 - AML/CTF programs of the AUSTRAC compliance guide for further information.

Last modified: 03/11/2016 15:00