Key personnel means each individual who is any of the following:

  • an individual with primary responsibility for the governance and executive decisions of the business (this may include an individual or multiple individuals who are part of a group)
  • a beneficial owner of the business
  • an individual who makes decisions or participates in making decisions that affect the whole or a major part of the business
  • the AML/CTF compliance officer of the business.

For a business that is an individual (sole trader), key personnel means the individual.

See

AML/CTF Rules 2025 section 1-4 Definitions