Ultimate Beneficial Owner (UBO) identification is a cornerstone of effective customer due diligence under the AML/CTF framework. Yet it remains one of the most challenging aspects of compliance, particularly when dealing with complex corporate structures, multi-layered trusts, or entities with opaque ownership arrangements.

This guide provides a comprehensive overview of UBO identification and verification, from understanding the definition to navigating complex ownership chains and applying fallback procedures when beneficial owners cannot be identified.

What is an Ultimate Beneficial Owner?

Under Australia's AML/CTF framework, a beneficial owner is defined as an individual who directly or indirectly:

• Ultimately owns or controls 25% or more of your customer

This definition contains three critical elements that shape how you conduct beneficial owner identification.

Critical Element 1: Must Be a Natural Person

The beneficial owner must always be an individual human being - a natural person. Corporate entities, trusts, partnerships, or other legal structures cannot be beneficial owners, even if they own or control your customer.

This means you must follow the ownership chain through multiple layers of corporate structures until you reach the individual people at the top.

Example: If BlueSky Holdings is owned by Apex Investments, which is owned by Summit Group, which is owned by three individuals (each holding 35%), those three individuals are the beneficial owners of BlueSky Holdings - not Apex Investments or Summit Group.

Critical Element 2: The 25% Threshold

The 25% ownership threshold is measured by either:

• Direct ownership: The individual directly owns 25% or more of the shares, units, or other ownership interests
• Indirect ownership: The individual owns 25% or more through intermediate entities

Example of indirect ownership: An individual owns 50% of Phoenix Enterprises, which owns 60% of Horizon Corporation (your customer). The individual's indirect ownership in Horizon Corporation is 30% (50% × 60% = 30%), so they are a beneficial owner.

Critical Element 3: Control Beyond Ownership

Importantly, beneficial ownership is not limited to formal shareholding. An individual who otherwise controls your customer is also a beneficial owner, even if they own less than 25% or nothing at all.

Control can be exercised through:

• Voting rights that differ from shareholding percentages
• Special veto powers or decision-making authority
• Appointment rights (ability to appoint or remove directors, trustees, or key decision-makers)
• Influence over trust distributions or administration
• Shareholder agreements that grant disproportionate control
• De facto control through family relationships, business arrangements, or other means

Example: An individual owns 15% of Vertex Manufacturing but has the contractual right to appoint the majority of directors. This individual controls the company and is therefore a beneficial owner, despite owning less than 25%.

Key Principles of UBO Identification

Your Customer May Have Multiple Beneficial Owners

It's common for a customer to have several beneficial owners. For example:

• A company with four equal shareholders (25% each) has four beneficial owners
• A family trust with three trustees who jointly control the trust may have three or more beneficial owners (including trustees, potentialy the settlor, and appointors)

Your Customer May Have No Beneficial Owners

Some customers legitimately have no beneficial owners because:

• No single individual owns or controls 25% or more
• Ownership is widely dispersed (e.g., a publicly listed company with thousands of shareholders)
• The customer is a government body

This is a valid outcome - and in this case the entity may be verified with a simplified procedure if certain conditions are met or the fallback UBO procedure will be used which is described below.

You Must Follow the Chain to Natural Persons

Never stop at a corporate entity. Always trace ownership and control through all intermediate structures until you reach individuals.

Example of the complete chain:

Your customer is The Thompson Family Trust

• Trustee: Thompson Corporate Trustees Pty Ltd (you must identify this company)
• Thompson Corporate Trustees Pty Ltd is owned by: Marcus Thompson (60%) and Isabella Thompson (40%) ✓ (beneficial owners identified)
• Appointor: Alexander Thompson ✓ (beneficial owner)
• Primary beneficiary: Thompson descendants (you identify the individual family members as beneficiaries)

In this example, the beneficial owners are Marcus Thompson, Isabella Thompson, and Alexander Thompson (all natural persons).

How to Identify 25% Ownership

Identifying ownership requires collecting and analyzing information about your customer's ownership structure.

Step 1: Collect Ownership Structure Information

You can collect information on:

• For body corporates, partnerships, and unincorporated associations:
  • Entity extracts
  • Board minutes
  • Ownership of the entity, including distribution of shares and types of shares
  • Duties, rights, and entitlements for administration
  • Control and decision-making processes
• For trusts:
  • Documents such as trust deeds, deeds of variation, unit registers
  • Control structure of the trust
  • Identity of settlors, appointors, guardians, and protectors
  • Duties, rights, and entitlements for trust administration
  • Control and decision-making processes

Step 2: Ask the Customer Directly (alternative)

If obtaining data from reliable data sources is not possible you can ask your customer's representative to provide information directly identifying all beneficial owners.

Your onboarding form could include questions like:

• "Please identify all individuals who own or control 25% or more of this entity"
• "Please provide details of any individuals who have the power to appoint or remove directors/trustees"
• "Please describe the ownership structure, including any intermediate entities"

Step 3: Calculate Ownership Percentages

For each individual in the ownership chain, calculate their ownership percentage:

Direct ownership: Straightforward percentage of shares or units held

Indirect ownership: Multiply ownership percentages through the chain

Example:

• Natasha Petrova owns 40% of Sterling Ventures
• Sterling Ventures owns 75% of Cascade Industries (your customer)
• Natasha Petrova's indirect ownership = 40% × 75% = 30%
• Therefore, Natasha Petrova is a beneficial owner of Cascade Industries

Step 4: Consider Multiple Ownership Paths

An individual might have ownership through multiple paths. Add these together to determine total ownership.

Example:

• Hassan Rahman directly owns 10% of Quantum Technologies
• Hassan Rahman also owns 50% of Nexus Capital, which owns 40% of Quantum Technologies
• Hassan Rahman's total ownership = 10% (direct) + 20% (indirect: 50% × 40%) = 30%
• Therefore, Hassan Rahman is a beneficial owner

How to Identify Control

Control is more nuanced than ownership and requires examining governance documents and practical decision-making authority.

Sources of Control to Investigate

Constitutional documents:

• Company constitution or trust deed
• Partnership agreements
• Shareholder agreements
• Memorandum and articles of association

Control mechanisms to look for:

• Appointment and removal rights for directors or trustees
• Veto powers over major decisions
• Special voting rights
• Control over distributions or dividends
• Reserved matters requiring specific approval
• De facto control arrangements

Practical Examples of Control

Example 1: Appointment RightsA company has three shareholders: Rajesh Kumar (45%), Sophia Lee (35%), and Carlos Rivera (20%). The shareholder agreement gives Carlos Rivera the right to appoint three of the five directors.

Result: All three individuals are beneficial owners - Rajesh and Sophia through ownership (>25%), and Carlos through control (appointment rights).

Example 2: Trust ControlThe Chen Discretionary Trust has a corporate trustee. Emily Chen is the appointor with the power to remove and appoint the trustee. Emily Chen controls the trust and is a beneficial owner, even if she owns nothing and is not a beneficiary.

Example 3: Protector PowersThe Nguyen Family Trust has a protector who must approve all distributions. The protector is Benjamin Nguyen. Benjamin Nguyen controls the trust through this veto power and is a beneficial owner.

Verifying Beneficial Owner Information

Once you've identified beneficial owners, you must verify both:

1. The ownership/control structure information
2. The identity of each beneficial owner

Verifying Ownership and Control Structure

For body corporates and partnerships:

• Company constitution, charter, or rules
• ASIC company extracts and registers
• Annual statements and amendments submitted to ASIC
• Shareholder registers
• Distribution of member statements
• Partnership agreements

For trusts:

• Trust deed
• Letters or documents from professional service firms
• Trustee resolutions
• Memorandum of trust
• Instrument of appointment (for appointors)

Verifying Beneficial Owner Identity

You verify the identity of a beneficial owner in exactly the same way you verify any individual - using reliable and independent source documentation.

The verification method should be appropriate to the customer's ML/TF risk:

• Low-risk customers: Standard individual verification may suffice
• High-risk customers: More robust verification, potentially including certified documents or in-person verification

Common verification methods:

• Government-issued photo ID (driver's license, passport)
• Electronic verification against government databases
• Certified copies of identity documents
• Biometric verification for high-risk cases

Risk-Based Approach to Verification

The AML/CTF framework requires more intensive verification for higher-risk situations:

• Collect more KYC information about beneficial owners of high-risk customers than low-risk customers
• Verify more thoroughly when the customer or beneficial owner is higher risk
• Apply enhanced due diligence measures when required (e.g., for politically exposed persons)

What Happens When You Cannot Identify Beneficial Owners

Despite your best efforts, you may encounter situations where you genuinely cannot identify the beneficial owners. The AML/CTF framework provides a fallback procedure for these circumstances.

The Fallback Procedure: CEO or Equivalent

If you're unable to establish the identity of any beneficial owners of a body corporate, partnership, or unincorporated association, you're still considered compliant if you:

1. Take all reasonable steps to identify beneficial owners
2. Record the steps taken and any difficulties encountered
3. Collect information about the individual who is the Chief Executive Officer (CEO) or equivalent
4. Verify that information as appropriate to the customer's ML/TF risk

What Are "Reasonable Steps"?

Reasonable steps would typically include:

• Asking the customer's representative to provide beneficial owner information
• Reviewing available corporate documents (constitution, shareholder agreements, ASIC extracts)
• Searching public registers for ownership information
• Requesting shareholder registers or ownership certificates
• Following up when information is incomplete or inconsistent
• Conducting database searches where available
• Requesting explanations for complex structures

The key is genuine effort - this isn't a shortcut to avoid the work. You must document that you tried to identify beneficial owners before falling back to the CEO.

Who is the "CEO or Equivalent"?

The "CEO or equivalent" means the senior managing official who has day-to-day operational control of the entity.

This could be:

• Chief Executive Officer
• Managing Director
• General Manager
• Executive Director
• President (if they manage operations, not just governance)
• Managing Partner (for partnerships)
• Principal
• Director (for smaller companies without a formal CEO)

Important: This should be the person with operational management control, not just governance oversight. A non-executive chairperson who only provides strategic oversight would may not be appropriate - you want the person who actually runs the business.

What About Trusts?

The fallback procedure described above applies to body corporates, partnerships, and unincorporated associations. The guidance does not provide an equivalent fallback for trusts.

For trusts, you must identify beneficial owners (which may include trustees, settlors, appointors, guardians, protectors, and controlling beneficiaries) unless a simplified procedure exception applies.

Documentation Requirements

When applying the fallback procedure, your records must show:

• The specific steps you took to try to identify beneficial owners
• Why those steps were unsuccessful
• What difficulties you encountered (e.g., "customer unable to provide shareholder register," "complex offshore structure with no public records")
• The identity of the CEO or equivalent and their role
• Verification evidence for the CEO/equivalent
• Your assessment that you took all reasonable steps

This documentation is critical for demonstrating compliance if questioned by AUSTRAC or during an audit.

Special Considerations for Different Entity Types

Body Corporates and Companies

Beneficial owners may include:

• Individual shareholders owning 25% or more
• Individuals controlling the company through voting rights, appointment powers, or shareholder agreements
• Individuals who are beneficial owners of corporate shareholders (follow the chain upward)

Key documents:

• ASIC company extract
• Shareholder register
• Company constitution
• Shareholder agreements
• Board resolutions

Trusts

Beneficial owners may include:

• Individual trustees
• Beneficial owners of corporate trustees (if the trustee is a company)
• Settlors (if they retain ongoing control or influence over the trust)
• Appointors
• Guardians
• Protectors
• Beneficiaries with control (typically in bare trusts or where beneficiaries have rights to appoint/remove trustees)

Important note on settlors: A settlor may not necessarily be a beneficial owner if their role was limited to setting up the trust and they have no ongoing controlling function or influence over the trust's administration or distributions. Always review the trust deed to determine whether the settlor retains any powers of control.

Key documents:

• Trust deed
• Instrument of appointment
• Trustee resolutions
• Letters from legal or accounting firms administering the trust

Important for trusts: You must identify the control structure, not just ownership. An appointor with no ownership stake may be the most significant beneficial owner due to their control powers.

Partnerships

Beneficial owners may include:

• Individual partners with 25% or more interest
• Partners with control through partnership agreement provisions
• Beneficial owners of corporate partners

Key documents:

• Partnership agreement
• Partnership register
• Distribution schedules

Unincorporated Associations

Beneficial owners may include:

• Individual members with 25% or more interest
• Committee members or office bearers with control
• Individuals with special powers under the association's rules

Key documents:

• Constitution or rules of association
• Membership register
• Committee meeting minutes

Common Pitfalls and How to Avoid Them

Pitfall 1: Stopping at a Corporate Entity

Wrong: Your customer is the Wilson Investment Trust with a corporate trustee (Wilson Trustees Pty Ltd). You identify Wilson Trustees Pty Ltd as the beneficial owner.

Right: You identify Wilson Trustees Pty Ltd as the trustee (a representative), then identify the individuals who own or control Wilson Trustees Pty Ltd as beneficial owners of the trust.

Pitfall 2: Ignoring Control in Favor of Ownership

Wrong: Focusing only on shareholding percentages and missing individuals who control through appointment rights, veto powers, or other mechanisms.

Right: Examining both ownership AND control, reviewing governance documents to identify all control mechanisms.

Pitfall 3: Not Following Indirect Ownership Chains

Wrong: Only looking at direct shareholders and missing indirect ownership through intermediate entities.

Right: Tracing ownership through all layers until you reach natural persons, calculating indirect ownership percentages.

Pitfall 4: Using the Fallback Too Quickly

Wrong: Asking the customer once for beneficial owner information, receiving an incomplete answer, and immediately falling back to the CEO.

Right: Making genuine, documented efforts to obtain beneficial owner information through multiple channels before resorting to the fallback procedure.

Pitfall 5: Poor Documentation

Wrong: Having no records showing how you identified beneficial owners or what steps you took when you couldn't.

Right: Maintaining clear records of information sources, calculation methods, verification evidence, and (when applicable) reasonable steps taken when beneficial owners couldn't be identified.

When You Don't Need to Identify Beneficial Owners: Simplified Procedures

Not every customer requires full beneficial owner identification and verification. Australia's AML/CTF framework recognises that certain low-risk customers already subject to robust oversight don't present the same ML/TF risks as other entities.

The Simplified Procedure Exception

You can skip beneficial owner identification and verification entirely if ALL of the following conditions are met:

1. The customer is LOW ML/TF risk
2. Enhanced CDD does NOT apply
3. The customer is, or is controlled by, one of the following:

Qualifying Entity Types

Government BodiesAny government body (federal, state, local, or foreign) is exempt from beneficial owner verification due to public accountability and transparency requirements.

Entities Subject to Regulatory OversightEntities regulated by prudential, insurance, or investor protection regulators through registration or licensing requirements, including:

• Banks
• Insurance companies
• Superannuation funds (APRA-regulated)
• Australian Financial Services licensees (ASIC-regulated)
• Credit licensees (ASIC-regulated)
• Registered auditors and liquidators (ASIC-regulated)

Strata and Community Title CorporationsCorporations or associations of homeowners in strata title or community title schemes, which have limited purposes and transparent governance.

Publicly Listed CompaniesCompanies that are both:

• Listed on a recognised exchange (e.g., ASX, NASDAQ, NYSE)
• Subject to public disclosure requirements ensuring beneficial ownership transparency

For publicly listed companies meeting these criteria, you also don't need to identify the CEO or equivalent.

The "Controlled By" Concept

Simplified procedures also apply when your customer is controlled by a qualifying entity, not just when they are one.

Example: A family trust controlled by a major ASX-listed bank qualifies for simplified procedures because the controlling entity (the bank) is a publicly listed company with disclosure requirements.

What You Still Must Verify

Even when simplified procedures apply, you must still:

• Verify the customer entity itself
• Verify all representatives who engage with you
• Verify persons receiving services on behalf of the customer
• Conduct PEP (politically exposed person) checks on individuals
• Conduct targeted financial sanctions screening

Why Simplified Procedures Make Sense

These exceptions exist because:

• Regulated entities are already subject to supervisory oversight that addresses ML/TF risks
• Government bodies have public accountability mechanisms
• Listed companies have mandatory disclosure regimes
• These customers present inherently lower ML/TF risk when properly assessed

Documenting Simplified Procedures

When applying simplified procedures, you must document:

• The customer's low ML/TF risk assessment
• Confirmation that enhanced CDD doesn't apply
• Evidence of the qualifying entity status (e.g., APRA registration number, ASX listing details)
• Your decision to apply simplified procedures

This documentation demonstrates compliance and provides an audit trail for future reference.

Practical Examples

Example 1: Simple Direct Ownership

Customer: Digital Solutions Pty Ltd

Ownership structure:

• Sophie Chen: 40%
• Michael O'Brien: 35%
• Jennifer Torres: 25%

Beneficial owners: Sophie Chen, Michael O'Brien, and Jennifer Torres (all own ≥25%)

Verification: Verify company ownership via ASIC extract and shareholder register. Verify identity of Sophie, Michael, and Jennifer using standard individual verification methods.

Example 2: Indirect Ownership Through Corporate Structure

Customer: Coastal Retail Pty Ltd

Ownership structure:

• Investment Holdings Pty Ltd: 100% of Coastal Retail
• Investment Holdings is owned by:
  • William Zhang: 60%
  • Olivia Patel: 40%

Beneficial owners: William Zhang and Olivia Patel (both have ≥25% indirect ownership of Coastal Retail)

Verification: Verify ownership chain through ASIC extracts for both companies and shareholder registers. Verify identity of William and Olivia.

Example 3: Control Through Appointment Rights

Customer: Metro Property Group Pty Ltd

Ownership structure:

• Thomas Anderson: 45%
• Rebecca Martinez: 30%
• Liam Foster: 25%

Additional information from shareholder agreement: Liam Foster has the right to appoint 4 of the 7 directors.

Beneficial owners: Thomas Anderson, Rebecca Martinez, and Liam Foster - all three are beneficial owners (Thomas and Rebecca through ownership >25%, Liam through both ownership of exactly 25% AND control via appointment rights)

Verification: Verify via ASIC extract, shareholder register, and shareholder agreement showing appointment rights. Verify identity of all three individuals.

Example 4: Complex Trust Structure

Customer: The Johnson Family Trust

Structure:

• Corporate Trustee: JFT Corporate Trustees Pty Ltd
  • Owned by: Katherine Johnson (60%), Daniel Johnson (40%)
• Settlor: Margaret Johnson
• Appointor: Elizabeth Johnson (power to remove and appoint trustee)
• Primary beneficiaries: Johnson grandchildren (no control rights)

Beneficial owners:

• Katherine Johnson (beneficial owner of corporate trustee, >25% ownership)
• Daniel Johnson (beneficial owner of corporate trustee, >25% ownership)
• Margaret Johnson (settlor - check trust deed to determine if she retains ongoing control powers)
• Elizabeth Johnson (appointor with control through appointment/removal powers)

Note: The Johnson grandchildren are beneficiaries but not beneficial owners unless they have control rights. Margaret Johnson's status as a beneficial owner depends on whether she retained any ongoing control functions beyond the initial settlement of the trust.

Verification: Verify via trust deed, ASIC extract for JFT Corporate Trustees, shareholder register, and instrument of appointment for Elizabeth. Verify identity of Katherine, Daniel, Margaret, and Elizabeth.

Example 5: Cannot Identify Beneficial Owners - Fallback Applied

Customer: Global Trade Partners Pty Ltd (assessed as low risk based on nature of business)

Attempts to identify beneficial owners:

1. Asked customer representative - advised ownership held through complex offshore trust structure
2. Requested trust documentation - customer unable to provide (governed by foreign law)
3. Searched ASIC registers - showed no beneficial ownership information
4. Followed up with customer twice - unable to obtain details
5. Assessed that further efforts unlikely to succeed given offshore structure

Documented difficulties: Complex offshore trust structure, foreign jurisdiction, customer unable to provide documentation

Fallback applied:

• Identified CEO: Christopher Hughes, Chief Executive Officer
• Collected: Full name, DOB, residential address
• Verified: Australian driver's license via electronic verification service
• Documented: All steps taken and why beneficial owners could not be identified

Outcome: Considered compliant with beneficial owner identification obligations through fallback procedure.

Example 6: Simplified Procedures - No UBO Identification Required

Customer: Australian Retirement Fund (superannuation fund)

Initial Assessment:

• ML/TF Risk: Low (established fund, transparent operations, regulated entity)
• Enhanced CDD: Not applicable
• Entity Type: APRA-regulated superannuation fund

Verification of Qualifying Status:

• Checked APRA website and confirmed registration as regulated superannuation fund
• Registration number: RSE L0001234
• Regulator: Australian Prudential Regulation Authority

Decision: Simplified procedures apply - all three conditions met

What was verified:

• ✓ The superannuation fund itself (via APRA register and trust deed)
• ✓ Authorised representatives: Amanda Wong (Fund Manager) and David Kim (Chief Investment Officer)
• ✓ PEP screening conducted on both representatives
• ✓ Targeted financial sanctions screening completed

What was NOT required:

• ✗ Beneficial owner identification (exempted under simplified procedures)
• ✗ Ownership structure analysis (not required for qualifying entities)
• ✗ CEO/equivalent fallback (not needed as simplified procedures apply)

Documentation:

• Record of APRA registration verification
• Low risk assessment rationale
• Confirmation that enhanced CDD not applicable
• Decision to apply simplified procedures per qualifying entity exception

Outcome: Compliant with CDD obligations without requiring beneficial owner verification, significantly reducing onboarding time and administrative burden while maintaining appropriate risk management.

Best Practices for UBO Identification

1. Start early in onboarding: Request beneficial owner information upfront, not as an afterthought
2. Use structured forms: Create clear onboarding forms that specifically ask for beneficial owner details and ownership structure diagrams
3. Educate customers: Many customers don't understand what you need - provide clear explanations and examples
4. Follow the chain systematically: Use organisational charts or diagrams to track complex ownership structures
5. Don't forget control: Always review governance documents for control mechanisms beyond simple shareholding
6. Document everything: Keep records of all information sources, calculations, and decision-making processes
7. Apply risk-based verification: Use more robust verification for higher-risk beneficial owners
8. Review periodically: Beneficial ownership can change - build reviews into your ongoing due diligence processes
9. Train your team: Ensure staff understand the difference between owners, controllers, representatives, and beneficial owners
10. Use technology: Consider using specialized software that can map ownership structures and calculate indirect ownership automatically

How Can bronID Help?

Identifying and verifying beneficial owners manually is complex, time-consuming, and prone to error - especially when dealing with multi-layered corporate structures, trusts, or entities with opaque ownership arrangements. bronID's eKYC platform automates and streamlines the entire UBO identification and verification process.

Automated Ownership Chain Investigation

bronID connects to different government registries and other public and commercial data sources to automatically investigate the chain of ownership and control. This includes:

• ASIC registers: Automatic extraction of company ownership, director information, and corporate structure details
• Government databases: Integration with official registries to verify entity status and registration
• Commercial data sources: Access to comprehensive business intelligence databases to trace complex ownership structures
• International registries: Connection to overseas corporate registries for entities with cross-border ownership

AI-Powered Document Analysis

bronID has an integrated AI engine that analyses uploaded documentation such as trust deeds, deeds of variation, shareholder agreements, and other relevant documentation to identify very accurately who has ownership and control over the entity. The AI engine:

• Extracts key information about trustees, settlors, appointors, guardians, and protectors from trust deeds
• Identifies control mechanisms such as appointment rights, veto powers, and special voting arrangements
• Calculates direct and indirect ownership percentages through complex corporate structures
• Flags potential beneficial owners based on both ownership thresholds and control mechanisms
• Recognises when settlors have retained ongoing control functions versus purely historical settlement roles

Automated Verification Workflows

Once beneficial owners are identified, bronID automatically sends requests for these individuals to be verified in accordance with the relevant IDV (Identity Verification) procedures. The platform:

• Triggers appropriate verification workflows based on customer risk assessment
• Supports multiple verification methods (document verification, biometric verification, electronic verification)
• Applies risk-based verification - more robust checks for higher-risk beneficial owners
• Manages the entire verification process from request to completion
• Provides real-time status updates and notifications

Comprehensive Screening and Risk Assessment

Once verification is completed, bronID automatically screens the entity and its UBOs for:

• PEPs (Politically Exposed Persons): Screening against global PEP databases to identify individuals in prominent public positions
• Sanctions: Checking against targeted financial sanctions lists including DFAT, UN, EU, OFAC, and other international sanctions regimes
• Criminal watchlists: Screening against law enforcement and criminal databases
• Negative media: Monitoring adverse media coverage related to financial crime, corruption, or other relevant concerns

Integrated Compliance Function

bronID provides you with a full overview of the ML/TF risk posed by a specific customer through its integrated compliance function:

• Risk scoring: Automated risk assessment based on beneficial owner profiles, entity type, jurisdiction, and screening results
• Simplified procedure detection: Automatic identification of customers qualifying for simplified procedures (APRA-regulated entities, ASX-listed companies, etc.) with evidence collection and documentation
• Fallback procedure management: Guided workflows for applying the CEO/equivalent fallback when beneficial owners cannot be identified, including documentation of reasonable steps
• IDV certificates: Comprehensive certificates documenting all verification steps, screening results, beneficial owner identification, and compliance decisions
• Audit trail: Complete record of all data sources, decisions, and evidence for regulatory audits and reviews
• Ongoing monitoring: Continuous screening for changes in beneficial ownership, PEP status, sanctions designations, and adverse media

Efficiency and Accuracy

By automating the UBO identification and verification process, bronID:

• Reduces onboarding time from days to minutes
• Eliminates manual errors in ownership calculations and chain tracing
• Ensures consistent application of compliance policies
• Provides comprehensive documentation for audit and regulatory purposes
• Enables your compliance team to focus on high-risk cases requiring human judgement
• Maintains up-to-date records through automated ongoing due diligence

Whether you're dealing with a simple company structure, a complex multi-layered trust, or an entity qualifying for simplified procedures, bronID handles the complexity while ensuring full compliance with Australia's AML/CTF requirements.

Summary

Identifying and verifying ultimate beneficial owners is fundamental to effective AML/CTF compliance. While it can be complex - particularly when dealing with multi-layered structures, trusts, or opaque offshore arrangements - a systematic approach makes the process manageable.

Remember the key principles:

• Beneficial owners must always be natural persons (individuals)
• The threshold is 25% ownership OR control
• You must follow the chain through all intermediate entities to reach individuals
• When you genuinely cannot identify beneficial owners, the fallback procedure (CEO or equivalent) provides compliance, but only after documenting reasonable efforts
• Documentation is critical - record your process, sources, and reasoning