Who is the beneficial owner of a trust under CDD

A search for “who is the beneficial owner of a trust” wants a name to put on the customer file. Under customer due diligence the answer is an individual, not the trust and not the corporate trustee as the stopping point. Checked against AUSTRAC’s initial CDD guide for a trust and the overview of initial customer due diligence on 2 October 2026. This is general information, not legal advice. This page does not reproduce those guides. The role list — trustee, appointor, beneficiaries — is beneficial owner of a trust: trustee, appointor, beneficiaries. Sector context is /tranche-2.

What “under CDD” changes

Customer due diligence asks you to establish who the beneficial owners are when the customer is not a natural person. On a trust file that question is answered on the CDD record, before you provide the designated service, unless a delay your program actually allows applies. The deed is the evidence. The email that opened the matter is not the evidence.

• The customer is the trust. Write the trust as the customer when the designated service is provided to the trust. Do not write the person who booked the meeting and call that the customer.
• The beneficial owner is an individual. A corporate trustee is a company in the structure. You still name the individuals who own or control. A company is not the person you stop on.
• The person acting is a separate line. The trustee, or a director of a corporate trustee, may be the person acting for the customer. That authority does not, by itself, make them the beneficial owner.
• Control can sit with someone who holds no units. An appointor who can remove the trustee can be the individual who controls the trust. They will not appear as a shareholder of the company the trust owns.

Who you name, and who you describe

This page is the CDD question. It is not the role catalogue. Read trustee, appointor, beneficiaries for which roles the deed may create. Read beneficial owner of shares: direct versus indirect when the trust is the indirect holder of company shares. The definition of ownership and control is what is a beneficial owner?. The rules overview is AML beneficial owner rules for Tranche 2.

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. Use KYC for each individual the program says you must verify. Those people are not bundled into the trust figure. If the program also requires you to verify a company in the structure, such as a corporate trustee, that company is a KYB check of its own. Confirm the live amounts on FreeAML pricing. FreeAML does not read the deed and does not decide who the beneficial owner is.

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