Trust CDD: settlor, appointor, trustee, beneficiaries
Trust customer due diligence asks which role each person holds. The settlor, the appointor, the trustee, and the beneficiaries are not four labels for the same signature on the engagement letter.
Quick answer
Start with the trustee you are dealing with. Then ask who can remove that trustee, who settled the trust, and which beneficiaries are named rather than described as a class. Control can make an appointor a beneficial owner without a distribution. Carve-outs for some settlors live in the trust guidance; this page does not restate them.
People search “trust UBO AML Australia” when a two-partner firm is engaged by a family trust and the deed shows a settlor, a corporate trustee, and an appointor who is not a beneficiary. 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. The control test itself is the beneficial owner of a trust. How a company trustee is checked is KYB versus KYC. The sector map is /tranche-2.
Four roles, four questions
A family trust deed is long, and the useful lines are short. The trustee is who you are dealing with, and if that trustee is a company the next step is the company, not a guess about the family. The appointor, sometimes called a principal, may control the trust by being able to change the trustee.
The settlor may be in scope, subject to carve-outs the trust guidance states and this page will not copy. Beneficiaries who are named are a different record from a class such as children.
- Trustee first. Identify the trustee. A company trustee is a KYB check, then the individuals the program requires behind that company.
- Appointor means control. A person who can hire and fire the trustee can be a beneficial owner without ever receiving a distribution.
- Settlor is a separate line. Do not skip the settlor because the deed is old. Read the carve-outs in the trust guidance instead of inventing one.
- Class is not a list of cousins. Record a class as a class. Identify the named beneficiaries the program tells you to identify now.
What the file should show
Roles on a trust customer file. This table does not reproduce AUSTRAC’s trust CDD guide.
| Role | Why it is on the file | What firms collapse |
|---|---|---|
| Trustee | The person or company the firm is dealing with | The trust name on the letterhead |
| Appointor | Control can make them a beneficial owner | A family friend with a reserve power, ignored |
| Settlor | In scope unless a carve-out in the guidance applies | Anyone who only contributed at the start, skipped unread |
| Beneficiary | Named people differ from a class description | Every relative who might one day benefit |
Where the roles page stops
This page separates the four roles. It is not the control test, and it is not the company-versus-person check. 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. Naming four roles on a diagram is not the same as the KYB check on a corporate trustee. Confirm the live amounts on FreeAML pricing. FreeAML does not name the beneficial owners of a trust or apply a settlor carve-out for you.
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Frequently Asked Questions
A corporate trustee is a KYB check. The people behind it are separate.
The firm suite is A$0. The client pays. Use KYB for the company or the trust and KYC for a person.
View pricingQuestions: team@freeaml.com.au