Beneficial owner of a company for CDD

Accountants meet this on a company file: a formation, a sale, or a client that is a proprietary company. The customer is the company. The beneficial owner is an individual behind it. AUSTRAC’s initial CDD guide for a body corporate is the company guide. The ownership and control tests are on determining ownership and control structures. Checked on 2 October 2026. This is general information, not legal advice. This page does not reproduce those guides. Sector context is /tranche-2.

The customer is the company

Write the company as the customer when the company is who you are providing the designated service to. The person who instructed you may be a director, an employee, or someone with no authority. Authority to give instructions is its own question. It does not make that person the beneficial owner. A personal KYC check on the caller, with the company left off the file, has not started company CDD.

Two ways an individual gets onto the list

The definition, and why control is not a second 25% test, is what a beneficial owner is. On a company file the short version is enough to know which question you are in. Either limb is enough. A company can have several beneficial owners, and sometimes the ownership limb names nobody.

Follow the chain past the next company

The ASIC extract of the customer often names another company as the member. That printout is the start. The beneficial owner is still an individual, so you follow the holding company until you reach people, or until you can say why you cannot. Where the extract stops is ultimate beneficial owner versus the ASIC extract. A public register you can look up instead of doing this work is not available as a substitute. Doing the CDD now, rather than waiting on register talk, is beneficial ownership register versus CDD.

A trust is a different customer

If the customer is a trust, this page is the wrong one. The deed, the trustee, the appointor, and the beneficiaries are the beneficial owner of a trust. A corporate trustee means you have both: the trust file, and this company question for the trustee. How the two guides sit together is AUSTRAC beneficial owner guidance for companies and trusts. Do not paste the company table onto a family trust.

KYB for the company. KYC for each person.

The FreeAML firm suite is A$0. The firm emails the client a link. The company is a KYB check. Each individual the program then requires is a personal KYC check, not a line inside the company price. 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. Confirm the live amounts on FreeAML pricing. What the client fills in on that check is the AML form. FreeAML does not decide who the beneficial owner is, and it does not read the share register for you.

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