AML beneficial owner rules for Tranche 2

People search “aml beneficial owner” when Tranche 2 has put a professional firm in front of a company or a trust and they want the rule in one place. The rule is not new in the Act. It is new work for firms that were outside the regime before 1 July 2026. Checked against AUSTRAC’s page on ownership and control, the initial CDD guide for a body corporate, and the initial CDD guide for a trust on 2 October 2026. This is general information, not legal advice. This page does not reproduce those guides. Who the reforms cover is on /tranche-2.

The rule, in one pass

• An individual. The beneficial owner you identify is a natural person. A company in the chain is a step.
• Ownership or control. Someone who ultimately owns 25% or more, directly or indirectly, is in on the ownership limb. Someone who controls the customer, directly or indirectly, can be in without that percentage. The definition is what is a beneficial owner?.
• Part of initial CDD. When the customer is not a person, establishing the beneficial owners is one of the matters in initial customer due diligence. The plain-English list of matters is customer due diligence requirements.
• The program still chooses depth. How far you verify depends on the risk and on your program. Naming a person is not the same as deciding the file is high risk.

Three files, three pages

This overview does not replace the page that matches the customer in front of you. Open the file that matches the structure, then come back here only for the map.

The company posts are ultimate beneficial owner versus the ASIC extract and AUSTRAC beneficial owner guidance for companies and trusts. The share post is beneficial owner of shares: direct versus indirect. The trust post is who is the beneficial owner of a trust under CDD. The role catalogue for a deed is trustee, appointor, beneficiaries. The collection steps are how to perform beneficial ownership checks.

What Tranche 2 adds, and what it does not

From 1 July 2026, a firm can be a reporting entity because it provides a designated service, including a professional service in table 6 or brokering real estate. The beneficial owner rule applies on those files when the customer is a company, a trust, or another customer that is not a natural person. It does not apply to a matter your program and AUSTRAC’s pages put outside the regime. A tax return that is outside does not grow a beneficial-owner appendix so the file looks complete.

Carve-outs, including where a listed public company or a government body changes the analysis, stay on AUSTRAC’s body-corporate guide. This overview does not copy them. If you cannot establish a beneficial owner after real effort, the fallback is on the definition page and in that guide. “The client did not know” is not the fallback.

What the client pays

On FreeAML the firm suite is A$0. The firm emails the client a link. Verification is client-pays. On the public list a personal KYC check is A$20 and a company or trust KYB check is A$40. Use KYB when the customer is a company or a trust. Each individual the program then requires is a separate KYC check, not a bundle inside the entity price. Confirm the live amounts on FreeAML pricing. FreeAML does not decide who the beneficial owner is, does not enrol the firm, and does not replace austrac.gov.au.

Frequently Asked Questions