Employees who sign for a company are not the customer

People search “AML check on employees who sign” when a two-partner firm has a signed engagement from a finance manager and is about to treat that manager as the client for CDD. Checked against AUSTRAC’s initial CDD guidance for a body corporate on 4 October 2026. This is general information, not legal advice. This page does not reproduce that guidance. Who owns or controls the company is the beneficial owner of a company. Why a company check is not a personal check is KYB versus KYC. The sector map is /tranche-2.

Authority to sign is a different question

Companies act through people, and the person who signs a costs agreement, a buyer’s instruction, or a resolution extract may be a director, or they may be an employee with a delegation. Authority answers whether the engagement is binding. Customer due diligence answers who the customer is and who owns or controls that customer, and AUSTRAC’s body-corporate guidance is the shape of the second question. This page does not reproduce it.

A two-partner firm that runs one personal check on the finance manager has a result for the manager, and it does not have KYB on the company, and it does not have the beneficial owners. The manager may not own a share. The people who do are still unnamed. That is the gap the phrase AML check on employees who sign is pointing at.

• Name the customer as the company. The engagement letter can be signed by a person. The CDD record names the company.
• Keep authority in its own line. You may note that the signatory could bind the company. That note is not a KYC result for the customer.
• Then look through. A company check, then the individuals the program’s ownership or control test names. Stop when the test stops, not when the signatory is convenient.
• Do not KYC the whole office. Staff who saw the email are not beneficial owners. Staff who sign are not beneficial owners unless the test says they are.

Signatory, customer, owner

An ASIC extract is not the same as the ownership test, which is ultimate beneficial owner versus an ASIC extract. Law firms as a sector are AML checks for lawyers.

Where the signatory page stops

This page is why the signing employee is not the customer. It is not the beneficial-owner test and it is not a board-resolution precedent. FreeAML does not decide who has authority to bind the company.

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. A personal check on the signatory is not the company KYB, and it is not a substitute price for the individuals the program names as beneficial owners. Confirm the live amounts on FreeAML pricing. FreeAML does not treat the signing employee as the customer or skip the company.

Frequently Asked Questions