AUSTRAC beneficial owner guidance for companies and trusts

People search “austrac beneficial owner” and want a single name. A company and a trust do not hand you that name in the same place. The company file starts with the ownership and control structure. The trust file starts with the deed. Checked against AUSTRAC’s guide for a body corporate, AUSTRAC’s guide for a trust, and determining ownership and control structures on 2 October 2026. This is general information, not legal advice. This page does not reproduce those guides. Sector context is /tranche-2.

A company: the email is not the owner

Harlow & Co Pty Ltd instructs a practice. The person who writes is a director and owns 15 percent. Two other people each own 40 percent, held through a second company. The ASIC extract of Harlow names that second company. It does not name the two people. The director is the person acting. The two people are the ownership question you still have to answer. How far an extract gets you, and where it stops, is ultimate beneficial owner versus the ASIC extract.

• Person acting. Authority to give instructions is its own matter. A director can have authority and still own 15 percent.
• Ownership limb. Someone who ultimately owns 25 percent or more is a beneficial owner without any extra control story. Follow the chain until you reach individuals.
• Control limb. Someone under that ownership figure can still control the company. The test is on AUSTRAC’s ownership page. Do not paste it from memory.

A trust: read the deed before you email anyone

The Ellison Family Trust has a corporate trustee. The appointor can remove that trustee and is not a named beneficiary. The beneficiary clause is a class: children and grandchildren. The person who booked the meeting is a director of the trustee company. That is three different roles, and only the deed tells you which of them exist. Who those roles are, in the language of a trust file, is beneficial owner of a trust.

If you can name a beneficiary, identify that person. If the class means you cannot name each one, AUSTRAC’s trust guide is the place that explains a description of the class. Use the words in the deed. Do not invent grandchildren, and do not stop at the word family. This page does not reproduce that guide.

When the trustee is a company, you have both files

A corporate trustee is a company in the trust file. You identify the company, then the individuals who own or control it, and you still deal with the appointor if the deed gives them control. The trust note covers the deed. The ASIC-extract note covers why the company printout will not show the appointor. Apply the trust guide to the trust and the company guide to the trustee. Do not use one checklist for both.

FreeAML runs the checks. It does not pick the owner.

The firm suite is A$0. Verification uses the client-pays entity path. On the public list a personal KYC check is A$20 and a company or trust KYB check is A$40. A person further along the deed or the share chain is a separate check, not a bundle. Confirm the live amounts on FreeAML pricing. FreeAML does not decide who the beneficial owner is, does not read the deed, and does not replace austrac.gov.au.

Frequently Asked Questions