SMSF buying property: who is the customer for CDD?

People search “SMSF property purchase AML CDD” when a tax practice is asked to “do the AML” on a self-managed super fund that is buying a rental, and the member list is longer than the trustee list. Checked against AUSTRAC’s initial CDD guide for a trust on 4 October 2026. This is general information, not legal advice. This page does not reproduce that guidance. Who is a beneficial owner when the customer is a trust is the beneficial owner of a trust. Company versus person checks are KYB versus KYC. The sector map is /tranche-2.

The fund is a trust, the customer is the trustee

A self-managed super fund buys through its trustee. The members benefit under the fund rules, and they are not, by that fact alone, the customer on the purchase. AUSTRAC’s trust CDD guide is the frame for a trust customer. This page does not reproduce it.

The tax practice first asks a prior question. Who is providing the designated service? If the agent or the conveyancer is the reporting entity on the purchase, the accountant does not become one by lodging the fund’s return. If the accountant’s own service is designated, the customer on that service is the trustee, and the program says which people behind that trustee are identified.

• Read the contract name. The purchaser on the contract is the clue to the trustee. A member who is not the contracting party is not added out of habit.
• Corporate trustee means a company. That is a KYB check, then the individuals the program names. Do not stop at the company name because the fund has an ABN.
• Individual trustees mean those people. Two trustees are two customers of that kind, not a single “fund” person. Each one the program requires is a separate check.
• Do not photocopy the member statement as CDD. Membership and trusteeship often overlap and sometimes do not. The overlap is a fact you check, not a shortcut.

Who is on the SMSF file

Sort the role before you sort the identity documents. The role decides the check. The member balance does not.

Where the SMSF page stops

This page is who the customer is on the fund’s purchase. It is not the beneficial-owner test for trusts and it is not the KYB-versus-KYC price note. Those are the beneficial owner of a trust and KYB versus KYC.

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. Identifying an SMSF trustee is not bundled into the firm suite, and a member list is not a pack of checks the suite includes. Confirm the live amounts on FreeAML pricing. FreeAML does not decide who the customer is on an SMSF purchase or treat every member as the customer.

Frequently Asked Questions