Discretionary trust buyer: who you must identify

People search “discretionary trust buyer AML” when a conveyancer on settlement has a buyer described only as a family trust and a list of relatives on the instruction sheet. Checked against AUSTRAC’s initial CDD guidance for trusts on 4 October 2026. This is general information, not legal advice. This page does not reproduce that guidance. The trust definition sits on who is the beneficial owner of a trust. Companies and trusts together are AUSTRAC beneficial owner guidance. The sector map is /tranche-2.

The contract name is not the list

A conveyance in the name of a discretionary trust arrives with a short label and a long deed, and the customer for the designated service is not whoever rang the office. AUSTRAC’s trust guidance is the shape of initial customer due diligence for a trust. You identify the trust, you identify the trustee, and you identify the individuals who own or control it under the test your program applies. This page does not reproduce that guidance and it does not list documents to collect instead of it.

Discretionary beneficiaries are the point people miss, and they may be a class, such as children and grandchildren, with no fixed percentage. A 25% ownership sum does not run cleanly through a hope of a distribution. Control, often through the appointor or principal who can change the trustee, is the limb that adds a real person, and the deed tells you the roles. The program tells you which roles you verify.

• Name the trust and the trustee separately. A corporate trustee is a company in the chain, not a substitute for the individuals who control the trust.
• Read the appointor. The person who can hire and fire the trustee is the name a percentage test skips. Record the role in the words the deed uses.
• Do not verify the whole class. A wide beneficiary class is not a list of customers. Verify the individuals the program’s test actually names.
• Do not stop at the sender. The accountant, the adult child, or the real estate agent who forwarded the contract is not the trust.

Who is on the buyer line

A second pass at the same definition is beneficial owner of a trust in Australia. Use it for the test. Use this page for the purchase file.

Where the trust-buyer page stops

This page is the discretionary trust as buyer on a conveyance. It is not the company-buyer page and it is not a deed summary. FreeAML does not interpret the deed or decide the control test.

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. The trust is a KYB check, and each individual the program requires is a separate KYC check, not a name bundled into the trust price. Confirm the live amounts on FreeAML pricing. FreeAML does not decide who controls the discretionary trust or who must be verified.

Frequently Asked Questions