Ultimate beneficial owner versus the name on the ASIC extract

This page is the gap between the extract and the person. It does not restate the ownership threshold or the control test. That definition is what is a beneficial owner?. It does not restate why a company check costs more than a personal check. That comparison is KYB versus KYC. Checked against AUSTRAC’s page on ownership and control on 2 October 2026. This is general information, not legal advice. Sector context is /tranche-2.

What the ASIC extract actually names

A current company extract is a registry snapshot. It can show the company, its officeholders, and the members of record. Those are legal names on a register. An ultimate beneficial owner is the individual who ultimately owns or controls the customer. The extract is a starting document. It is not the conclusion.

Follow the chain, including control

Company A owned by Company B owned by two people is two extracts and then those two people, not one licence photo of the director who emailed you. Stop at a natural person, or at a carve-out your program and AUSTRAC’s guidance actually allow. A listed company or a government body can change the analysis. A private company sitting beside one does not inherit that outcome. If you cannot find an owner after real effort, the fallback is on the beneficial-owner page. 'The extract was enough' is not the fallback.

Control is why a small name on the register can still matter, and why a large name can be a nominee. Someone under the ownership threshold can control the board or the votes. Someone who owns the shares on paper can hold them for a trust. The extract will not tell you which. Ask who can direct the company in practice, then identify that individual. The collection steps are how to perform beneficial ownership checks. What initial due diligence has to establish, including beneficial owners where the customer is not a person, is customer due diligence requirements.

Trusts and nominees are not on the first page

A family trust that owns the shares often appears, if it appears at all, as a trustee company or as a person’s name 'as trustee'. The appointor who can change the trustee may not be a member. AUSTRAC’s customer guidance points firms at settlors, appointors, guardians, and protectors when those roles exist. The label on the deed is a clue. The test is still which individual owns or controls. Do not paste a company-extract checklist onto every trust.

On a company formation, the customer list can include proposed beneficial owners before any extract exists. That service test is AML for accountants. On a members’ voluntary liquidation, you still do not open a personal file for every small holder. That boundary is MVL shareholder KYC. On a listing, a vendor that is a company is the entity, not the person who signed the authority: who is the customer on a real estate sale.

Where FreeAML fits

Complex ownership is a company check, then the people the program names. The firm suite is A$0. Verification is client-pays by email. On the public list, a personal KYC check is A$20 and a company KYB check is A$40. A person further along the chain is not bundled into the company figure. Confirm the live amounts on FreeAML pricing before you quote. The product can collect the evidence. It does not decide who the ultimate beneficial owner is, and it does not apply the control test for you. If the chart is unclear, get advice before you email the wrong person.

Frequently Asked Questions