After two rounds of public consultation, on 29 August 2025 AUSTRAC tabled the new Anti-Money Laundering and Counter-Terrorism Financing Rules 2025 in Parliament. One of the biggest updates was the introduction of new initial customer due diligence (CDD) requirements in Section 6 of the Rules. These replace - and in some ways re-shape - the current customer identification procedures found in Chapter 4 of the AML/CTF Rules 2007.
When the updated Rules were first reviewed, the new initial CDD framework appeared broader, less prescriptive, and more flexible than the existing Chapter 4 requirements. Our early assessment suggested that major operational changes might not be necessary, other than strengthening and formalising a more risk-based approach.
This changed on 17 October 2025 when AUSTRAC released reform guidance to help reporting entities comply with the new legislation. The guidance includes a detailed section on CDD and provides AUSTRAC’s interpretation of how the new Rules should be applied. While helpful, the guidance is noticeably more prescriptive and, in places, effectively expands on the requirements contained in the Rules themselves.
It’s important to understand that AUSTRAC’s guidance explains how the regulator interprets the Act and the Rules. It is not legally binding and cannot override or replace legislation. The Act and the Rules are the actual law, and only the courts can authoritatively determine their meaning and decide whether a breach has occurred. Guidance reflects AUSTRAC’s expectations, not new legal obligations, but it still carries practical weight because it shows how AUSTRAC will assess compliance.
| Instrument | Legal Status | Binding? | Purpose | Level of Detail | Who Interprets It |
|---|---|---|---|---|---|
| AML/CTF Act 2006 | Law passed by Parliament | Yes – fully enforceable | Defines the full legal framework and core obligations | High-level principles and duties | Ultimately the courts |
| AML/CTF Rules | Legislative instruments under the Act | Yes – enforceable | Explains how to meet the obligations in the Act | Detailed, practical requirements | Courts and AUSTRAC |
| AUSTRAC Guidance | Regulator-issued guidance | No – not enforceable | Describes AUSTRAC’s preferred interpretation and expectations | Detailed but advisory | AUSTRAC (persuasive only for courts) |
bronID Position and Next Steps
Although the guidance is not enforceable in its own right, most reporting entities prefer to follow it closely because it shows how AUSTRAC expects the law to be applied in practice. As a result, service providers like bronID need to align with these expectations and support customers in meeting them.
Over the past month we have completed a detailed review of the new guidance and prepared a comparative table outlining the differences. Based on this review, bronID will be updating some of the KYB procedures that run in the background for all entity types. Fortunately, because bronID has always taken a conservative and robust approach to CDD, only modest adjustments are needed in most cases.
We will also be rolling out new tools to give you greater transparency and control over your KYB data and results. Below you will find an outline of the upcoming changes to bronID’s KYB procedures, which will take effect from 31 March 2026.
Sole traders
| bronID Existing Procedures | bronID New Procedures | |||||
|---|---|---|---|---|---|---|
| Parameter | Collect | Verify | Verification Method | Chapter 4 AML/CTF Rules 2007/AUSTRAC Easy Reference Guide | Part 6 AML/CTF Rules 2025/AUSTRAC Tranche 2 CDD Guidance | Change |
| Evidence of existence | Yes | Yes | ABR (Australian Business Number if business is registered) | The existence of the sole trader is verified with the ABR | The existence of the sole trader is verified with the ABR | NO |
| Business name used for conduct of business | Yes | Yes | ABN information from Australian Business Register | All business names are collected from the ABR | All business names are collected from the ABR | NO |
| Other names the business is commonly known by | Yes | No | All business names are collected from the ABR | All business names are collected from the ABR | NO | |
| Unique identifier for the business (if any) | Yes | Yes | ABR (Australian Business Number if business is registered) | The ABN is verified with the ABR | The ABN is verified with the ABR | NO |
| Address of principal place of business | Yes | No | This is collected from the customer | This is collected as the residential address of the customer | NO/SOME | |
| Identity of the individual | Yes | Yes* | Individual identity verification guidance | The individual is verified in accordance with the individual verification procedure | The individual is verified in accordance with the individual verification procedure | NO |
| Nature of the entity (general commercial activity or sector, and kinds of products and services it offers) | Yes | No | NA | Collected from the customer and/or secondary sources | YES | |
Australian Company
| bronID Existing Procedures | bronID New Procedures | |||||
|---|---|---|---|---|---|---|
| Parameter | Collect | Verify | Verification Method | Chapter 4 AML/CTF Rules 2007/AUSTRAC Easy Reference Guide | Part 6 AML/CTF Rules 2025/AUSTRAC Tranche 2 CDD Guidance | Change |
| Evidence of existence | Yes | Yes | ASIC registers (company name and ACN search); Certificate of incorporation or registration | The existence of the company is verified with ASIC | The existence of the company is verified with ASIC | NO |
| Full name (as registered with ASIC) | Yes | Yes | ASIC registers (company name and ACN search) | The full name is verified with ASIC | The full name is verified with ASIC | NO |
| ACN (Australian Company Number) | Yes | Yes | ASIC registers (company name and ACN search) | The ACN is verified with ASIC/ABR | The ACN is verified with ASIC/ABR | NO |
| Business names | Yes | No | All business names are collected from the ABR | All business names are collected from the ABR | NO | |
| Other names commonly known by | Yes | No | All business names are collected from the ABR | All business/trade names are collected from ABR | NO | |
| ABN (if applicable) | Yes | No | ABR (if the entity has an ABN) | The ABN is collected/verified with the ABR where applicable | The ABN is collected/verified with the ABR where applicable | NO |
| Principal place of business address | Yes | No | The place of business address is collected from ASIC | The place of business address is collected from ASIC | NO | |
| Registered office address (if different from principal place) | Yes | No | The registered office address is collected from ASIC | The registered office address is collected from ASIC | NO | |
| Full names of directors/board members | Yes | No | The names of the directors are collected from ASIC | The names of the directors are collected from ASIC | NO | |
| Director identification numbers (where applicable) | Yes | No | NA | DINs may be collected, but not verified | YES | |
| Identity of any beneficial owners | Yes | Yes* | Individual identity verification guidance | UBOs are identified and verified | UBOs are identified and verified | SOME |
| Nature of the entity (general commercial activity or sector, and kinds of products and services it offers) | Yes | No | NA | Collected from the customer and/or secondary sources | YES | |
Registered Foreign Company
| bronID Existing Procedures | bronID New Procedures | |||||
|---|---|---|---|---|---|---|
| Parameter | Collect | Verify | Verification Method | Chapter 4 AML/CTF Rules 2007/AUSTRAC Easy Reference Guide | Part 6 AML/CTF Rules 2025/AUSTRAC Tranche 2 CDD Guidance | Change |
| Evidence of existence | Yes | Yes | ASIC registers (company name and ARBN search); Certificate of incorporation or registration | The existence of the company is verified with ASIC | The existence of the company is verified with ASIC | NO |
| Full name (as registered with ASIC) | Yes | Yes | ASIC registers (company name and ARBN search) | The full name is verified with ASIC | The full name is verified with ASIC | NO |
| ARBN (Australian Registered Body Number) | Yes | Yes | ASIC registers (company name and ARBN search) | The ARBN is verified with ASIC | The ARBN is verified with ASIC | NO |
| Whether registered with relevant foreign registration body | Yes | Yes | ASIC registers (company name and ARBN search); Certificate of incorporation or registration | The entity is verified with the foreign corporate register | The entity is verified with the foreign corporate register | NO |
| Whether registered as private or public company | Yes | Yes | ASIC registers (company name and ARBN search); Certificate of incorporation or registration | The type of entity is verified with ASIC and foreign registers | The type of entity is verified with ASIC and foreign registers | NO |
| Business names | Yes | No | All business names are collected from the foreign corporate register (where applicable) | All business names are collected from the foreign corporate register (where applicable) | NO | |
| Other names commonly known by | Yes | No | All business names are collected from the foreign corporate register (where applicable) | All business names are collected from the foreign corporate register (where applicable) | NO | |
| ABN (if applicable) | Yes | No | ABR (if the entity has an ABN) | The ABN is collected/verified with the ABR where applicable | The ABN is collected/verified with the ABR where applicable | NO |
| Principal place of business address | Yes | No | The place of business address is collected from ASIC or foreign corporate register | The place of business address is collected from ASIC or foreign corporate register | NO | |
| Registered office address (if different from principal place) | Yes | No | The registered office address is collected from ASIC or foreign corporate register (where applicable) | The registered office address is collected from ASIC or foreign corporate register (where applicable) | NO | |
| Full names of directors/board members | Yes | No | The names of the directors are collected from ASIC and/or foreign corporate register | The names of the directors are collected from ASIC and/or foreign corporate register | NO | |
| Director identification numbers (where applicable) | Yes | No | NA | Usually not applicable for foreign companies | NO | |
| Identity of any beneficial owners | Yes | Yes* | Individual identity verification guidance | UBOs are identified and verified | UBOs are identified and verified | SOME |
| Nature of the entity (general commercial activity or sector, and kinds of products and services it offers) | Yes | No | NA | Collected from the customer and/or secondary sources | YES | |
Unregistered Foreign Company
| bronID Existing Procedures | bronID New Procedures | |||||
|---|---|---|---|---|---|---|
| Parameter | Collect | Verify | Verification Method | Chapter 4 AML/CTF Rules 2007/AUSTRAC Easy Reference Guide | Part 6 AML/CTF Rules 2025/AUSTRAC Tranche 2 CDD Guidance | Change |
| Evidence of existence | Yes | Yes | Foreign government/commercial registers | The existence of the company is verified with foreign corporate and commercial registers. In some cases with offshore entities, the existence may be verified with authorised agent disclosures. | The existence of the company is verified with foreign corporate and commercial registers. In some cases with offshore entities, the existence may be verified with authorised agent disclosures. | NO |
| Full name | Yes | Yes | Foreign government/commercial registers | The full name of the company is verified with foreign corporate and commercial registers. | The full name of the company is verified with foreign corporate and commercial registers. | NO |
| Whether registered by relevant foreign registration body | Yes | Yes | Foreign government/commercial registers | The company is verified with foreign corporate and commercial registers. | The company is verified with foreign corporate and commercial registers. | NO |
| Identification number issued by foreign registration body | Yes | Yes | Foreign government/commercial registers | The unique company identifiers are collected and verified with the foreign corporate and commercial registers. In some cases with offshore entities, the identifiers may be verified with authorised agent disclosures. | The unique company identifiers are collected and verified with the foreign corporate and commercial registers. In some cases with offshore entities, the identifiers may be verified with authorised agent disclosures. | NO |
| Business names | Yes | No | All business names are collected from the foreign corporate register (where applicable) | All business names are collected from the foreign corporate register (where applicable) | NO | |
| Other names commonly known by | Yes | No | All business names are collected from the foreign corporate register (where applicable) | All business names are collected from the foreign corporate register (where applicable) | NO | |
| Principal place of business address | Yes | No | The place of business address is collected from the foreign corporate register | The place of business address is collected from the foreign corporate register | NO | |
| Registered office address (if different from principal place) | Yes | No | The registered office address is collected from foreign corporate register (where applicable) | The registered office address is collected from foreign corporate register (where applicable) | NO | |
| Full names of directors/board members | Yes | No | The names of the directors are collected from the foreign corporate register. For certain countries where this is not possible, the names of the directors are collected directly from the customer. | The names of the directors are collected from the foreign corporate register. For certain countries where this is not possible, the names of the directors are collected directly from the customer. | NO | |
| Identity of any beneficial owners | Yes | Yes* | Individual identity verification guidance | UBOs are identified and verified | UBOs are identified and verified | SOME |
| Nature of the entity (general commercial activity or sector, and kinds of products and services it offers) | Yes | No | NA | Collected from the customer and/or secondary sources | YES | |
Partnership
| bronID Existing Procedures | bronID New Procedures | |||||
|---|---|---|---|---|---|---|
| Parameter | Collect | Verify | Verification Method | Chapter 4 AML/CTF Rules 2007/AUSTRAC Easy Reference Guide | Part 6 AML/CTF Rules 2025/AUSTRAC Tranche 2 CDD Guidance | Change |
| Evidence of existence | Yes | Yes | Partnership agreement (original, reliable copy or extract), ASIC, ABR | The partnership existence is verified by reviewing the partnership deed, ABR or ASIC | The partnership existence is verified by reviewing the partnership deed, ABR or ASIC | NO |
| Full name | Yes | Yes | Partnership agreement (original, reliable copy or extract), ASIC, ABR | The partnership name is verified by reviewing the partnership deed, ABR or ASIC | The partnership name is verified by reviewing the partnership deed, ABR or ASIC | NO |
| ABN of the partnership business (if any) | Yes | Yes | ASIC, ABR (where applicable) | The ABN is verified with the ABR (where applicable) | The ABN is verified with the ABR (where applicable) | NO |
| Names of all partners (if no partnership name) | Yes | No | The names of the partners are verified from the partnership deed | The names of the partners are verified from the partnership deed | NO | |
| Business names | Yes | No | All business names are collected from ABR/ASIC | All business names are collected from ABR/ASIC | NO | |
| Other names commonly known by | Yes | No | All business/trade names are collected from ABR | All business/trade names are collected from ABR | NO | |
| Principal place of business address | Yes | No | The principal place of business is collected from self-disclosure or the partnership agreement | The principal place of business is collected from self-disclosure or the partnership agreement | NO | |
| Registered office address (if different from principal place) | Yes | No | The registered office is collected from self-disclosure or the partnership agreement (where applicable) | The registered office is collected from self-disclosure or the partnership agreement (where applicable) | NO | |
| Partnership agreement | Yes | No | The partnership agreement is collected from the customer | The partnership agreement is collected from the customer | NO | |
| Full names of all partners | Yes | No | The partners are collected from the partnership agreement or associated deeds. They may also be collected from government registers such as ASIC or foreign registers. | The partners are collected from the partnership agreement or associated deeds. They may also be collected from government registers such as ASIC or foreign registers. | NO | |
| Identity of any beneficial owners | Yes | Yes* | Individual identity verification guidance | UBOs are identified and verified | UBOs are identified and verified | SOME |
| Nature of the entity (general commercial activity or sector, and kinds of products and services it offers) | Yes | No | NA | Collected from the customer and/or secondary sources | YES | |
Incorporated Association
| bronID Existing Procedures | bronID New Procedures | |||||
|---|---|---|---|---|---|---|
| Parameter | Collect | Verify | Verification Method | Chapter 4 AML/CTF Rules 2007/AUSTRAC Easy Reference Guide | Part 6 AML/CTF Rules 2025/AUSTRAC Tranche 2 CDD Guidance | Change |
| Evidence of existence | Yes | Yes | State Association Register, ABR, ACNC | The association existence is verified with the ABR, ACNC or the State Association register, or a combination. | The association existence is verified with the ABR, ACNC or the State Association register, or a combination. | NO |
| Full name | Yes | Yes | State Association Register, ABR, ACNC | The association name is verified with the ABR, ACNC or the State Association register, or a combination. If this is not possible then a reliable document is collected such as the Constitution, Rules, Board Minutes or similar. | The association name is verified with the ABR, ACNC or the State Association register, or a combination. If this is not possible then a reliable document is collected such as the Constitution, Rules, Board Minutes or similar. | NO |
| Names of all members (if no association name) | Yes | No | NO | |||
| Business names | Yes | No | All business names are collected from ABR (if applicable) | All business names are collected from ABR (if applicable) | NO | |
| Other names commonly known by | Yes | No | All business/trade names are collected from ABR (if applicable) | All business/trade names are collected from ABR (if applicable) | NO | |
| Unique identifier (if any - may not be available) | Yes | Yes (if applicable) | State Association Register, ABR, ACNC | The association number or ABN is verified with the ABR, ACNC or the State Association register, or a combination. | The association number or ABN is verified with the ABR, ACNC or the State Association register, or a combination. | NO |
| Principal place of business address | Yes | No | The principal place of business address is collected from the ACNC or the State Association register, or a combination. When this is not possible, the address is collected from the customer. | The principal place of business address is collected from the ACNC or the State Association register, or a combination. When this is not possible, the address is collected from the customer. | NO | |
| Registered office address (if different from principal place) | Yes | No | The registered office address is collected from the ACNC or the State Association register, or a combination. When this is not possible, the address is collected from the customer. | The registered office address is collected from the ACNC or the State Association register, or a combination. When this is not possible, the address is collected from the customer. | NO | |
| Constitution or rules of association | Yes | No | Collected only when needed, if association extract or ACNC extract is not available. Alternatively collected from ACNC, the state association register or the customer. | Collected only when needed, if association extract or ACNC extract is not available. Alternatively collected from ACNC, the state association register or the customer. | NO | |
| Full names of committee members | Yes | No | The committee members and the relevant officeholders are collected from ACNC or the state association register. If this is not possible, they are collected from the customer by requesting relevant documents. | The committee members and the relevant officeholders are collected from ACNC or the state association register. If this is not possible, they are collected from the customer by requesting relevant documents. | NO | |
| Identity of any beneficial owners | Yes | Yes* | Individual identity verification guidance | UBOs are identified and verified | UBOs are identified and verified | SOME |
| Nature of the entity (general commercial activity or sector, and kinds of products and services it offers) | Yes | No | NA | Collected from the customer and/or secondary sources | YES | |
Unincorporated Association
| bronID Existing Procedures | bronID New Procedures | |||||
|---|---|---|---|---|---|---|
| Parameter | Collect | Verify | Verification Method | Chapter 4 AML/CTF Rules 2007/AUSTRAC Easy Reference Guide | Part 6 AML/CTF Rules 2025/AUSTRAC Tranche 2 CDD Guidance | Change |
| Evidence of existence | Yes | Yes | Rules, constitution of association or equivalent (original, copy or extract), ABR, ACNC | The association existence is verified with the ABR or ACNC; if this is not possible, then relevant documents such as the Constitution, Rules and Disclosure Certificates are collected. | The association existence is verified with the ABR or ACNC; if this is not possible, then relevant documents such as the Constitution, Rules and Disclosure Certificates are collected. | NO |
| Full name from rules or constitution | Yes | Yes | Rules, constitution of association or equivalent (original, copy or extract), ABR, ACNC | The association name is verified with the ABR or ACNC; if this is not possible, then relevant documents such as the Constitution, Rules and Disclosure Certificates are collected. | The association name is verified with the ABR or ACNC; if this is not possible, then relevant documents such as the Constitution, Rules and Disclosure Certificates are collected. | NO |
| Names of all members (if no association name) | Yes | No | NO | |||
| Business names | Yes | No | All business names are collected from ABR (if applicable) | All business names are collected from ABR (if applicable) | NO | |
| Other names commonly known by | Yes | No | All business/trade names are collected from ABR (if applicable) | All business/trade names are collected from ABR (if applicable) | NO | |
| Unique identifier (if any - may not be available) | Yes | Yes (if applicable) | ABR (if the entity has an ABN) | The ABN is verified with the ABR. Usually Unincorporated Associations do not have other numbers. | The ABN is verified with the ABR. Usually Unincorporated Associations do not have other numbers. | NO |
| Principal place of business address | Yes | No | The principal place of business address is collected from the ACNC. When this is not possible because the entity is not a charity, the address is collected from the customer. | The principal place of business address is collected from the ACNC. When this is not possible because the entity is not a charity, the address is collected from the customer. | NO | |
| Registered office address (if different from principal place) | Yes | No | The registered office address is collected from the ACNC. When this is not possible because the entity is not a charity, the address is collected from the customer. | The registered office address is collected from the ACNC. When this is not possible because the entity is not a charity, the address is collected from the customer. | NO | |
| Constitution or rules of association | Yes | No | NO | |||
| Full names of committee members | Yes | No | The committee members and the relevant officeholders are collected from ACNC. If this is not possible because the entity is not a charity, they are collected from the customer by requesting relevant documents. | The committee members and the relevant officeholders are collected from ACNC. If this is not possible because the entity is not a charity, they are collected from the customer by requesting relevant documents. | NO | |
| Identity of any beneficial owners | Yes | Yes* | Individual identity verification guidance | UBOs are identified and verified | UBOs are identified and verified | SOME |
| Nature of the entity (general commercial activity or sector, and kinds of products and services it offers) | Yes | No | NA | Collected from the customer and/or secondary sources | YES | |
Registered Co-operative
| bronID Existing Procedures | bronID New Procedures | |||||
|---|---|---|---|---|---|---|
| Parameter | Collect | Verify | Verification Method | Chapter 4 AML/CTF Rules 2007/AUSTRAC Easy Reference Guide | Part 6 AML/CTF Rules 2025/AUSTRAC Tranche 2 CDD Guidance | Change |
| Official extract from co-operatives register (evidence of existence) | Yes | Yes | Official extract from state/territory co-operatives register | The co-operative existence is verified with the ABR, ACNC or the relevant State Register, or a combination. | The co-operative existence is verified with the ABR, ACNC or the relevant State Register, or a combination. | NO |
| Full name | Yes | No | The co-operative name is verified with the ABR, ACNC or the relevant State Register, or a combination. If this is not possible, then a reliable document is collected such as the Constitution, Rules, Board Minutes or similar. | The co-operative name is verified with the ABR, ACNC or the relevant State Register, or a combination. If this is not possible, then a reliable document is collected such as the Constitution, Rules, Board Minutes or similar. | NO | |
| Business names | Yes | No | All business names are collected from ABR (if applicable) | All business names are collected from ABR (if applicable) | NO | |
| Other names commonly known by | Yes | No | All business/trade names are collected from ABR (if applicable) | All business/trade names are collected from ABR (if applicable) | NO | |
| Unique identifier (if any) | Yes | Yes (if applicable) | ABR (if the entity has an ABN) | The co-operative unique identifier is verified with the ABR, ACNC or the relevant State Register, or a combination. If this is not possible, then a reliable document is collected such as the Constitution, Rules, Board Minutes or similar. | The co-operative unique identifier is verified with the ABR, ACNC or the relevant State Register, or a combination. If this is not possible, then a reliable document is collected such as the Constitution, Rules, Board Minutes or similar. | NO |
| Principal place of business address | Yes | No | The principal place of business address is collected from the ACNC or the relevant State Register, or a combination. When this is not possible, the address is collected from the customer. | The principal place of business address is collected from the ACNC or the relevant State Register, or a combination. When this is not possible, the address is collected from the customer. | NO | |
| Registered office address (if different from principal place) | Yes | No | The registered office address is collected from the ACNC or the relevant State Register, or a combination. When this is not possible, the address is collected from the customer. | The registered office address is collected from the ACNC or the relevant State Register, or a combination. When this is not possible, the address is collected from the customer. | NO | |
| Constitution or equivalent document | Yes | No | NO | |||
| Full names of board members | Yes | No | The committee members and the relevant officeholders are collected from ACNC. If this is not possible because the entity is not a charity, they are collected from the customer by requesting relevant documents. | The committee members and the relevant officeholders are collected from ACNC. If this is not possible because the entity is not a charity, they are collected from the customer by requesting relevant documents. | NO | |
| Identity of any beneficial owners | Yes | Yes* | Individual identity verification guidance | UBOs are identified and verified | UBOs are identified and verified | SOME |
| Nature of the entity (general commercial activity or sector, and kinds of products and services it offers) | Yes | No | NA | Collected from the customer and/or secondary sources | YES | |
Registered indigenous corporation
| bronID Existing Procedures | bronID New Procedures | |||||
|---|---|---|---|---|---|---|
| Parameter | Collect | Verify | Verification Method | Chapter 4 AML/CTF Rules 2007/AUSTRAC Easy Reference Guide | Part 6 AML/CTF Rules 2025/AUSTRAC Tranche 2 CDD Guidance | Change |
| Evidence of existence | Yes | Yes | Official extract from ACNC and ORIC | The indigenous corporation existence is verified with the ABR, ACNC or ORIC or a combination. | The indigenous corporation existence is verified with the ABR, ACNC or ORIC, or a combination. | NO |
| Full name | Yes | No | The indigenous corporation name is verified with the ABR, ACNC or ORIC, or a combination. If this is not possible, then a reliable document is collected such as the Constitution, Rules, Board Minutes or similar. | The indigenous corporation name is verified with the ABR, ACNC or ORIC, or a combination. If this is not possible, then a reliable document is collected such as the Constitution, Rules, Board Minutes or similar. | NO | |
| Business names | Yes | No | All business names are collected from ABR (if applicable) | All business names are collected from ABR (if applicable) | NO | |
| Other names commonly known by | Yes | No | All business/trade names are collected from ABR (if applicable) | All business/trade names are collected from ABR (if applicable) | NO | |
| Unique identifier (if any) | Yes | Yes (if applicable) | ABR (if the entity has an ABN) | The indigenous corporation unique identifier is verified with the ABR, ACNC or ORIC, or a combination. If this is not possible, then a reliable document is collected such as the Constitution, Rules, Board Minutes or similar. | The indigenous corporation unique identifier is verified with the ABR, ACNC or ORIC, or a combination. If this is not possible, then a reliable document is collected such as the Constitution, Rules, Board Minutes or similar. | NO |
| Principal place of business address | Yes | No | The principal place of business address is collected from the ACNC or ORIC, or a combination. When this is not possible, the address is collected from the customer. | The principal place of business address is collected from the ACNC or ORIC, or a combination. When this is not possible, the address is collected from the customer. | NO | |
| Registered office address (if different from principal place) | Yes | No | The registered office address is collected from the ACNC or ORIC, or a combination. When this is not possible, the address is collected from the customer. | The registered office address is collected from the ACNC or ORIC, or a combination. When this is not possible, the address is collected from the customer. | NO | |
| Constitution or equivalent document | Yes | No | NO | |||
| Full names of board members | Yes | No | The committee members and the relevant officeholders are collected from ACNC and/or ORIC. If this is not possible because the entity is not a charity, they are collected from the customer by requesting relevant documents. | The committee members and the relevant officeholders are collected from ACNC and/or ORIC. If this is not possible because the entity is not a charity, they are collected from the customer by requesting relevant documents. | NO | |
| Identity of any beneficial owners | Yes | Yes* | Individual identity verification guidance | UBOs are identified and verified | UBOs are identified and verified | SOME |
| Nature of the entity (general commercial activity or sector, and kinds of products and services it offers) | Yes | No | NA | Collected from the customer and/or secondary sources | YES | |
Trust
| bronID Existing Procedures | bronID New Procedures | |||||
|---|---|---|---|---|---|---|
| Parameter | Collect | Verify | Verification Method | Chapter 4 AML/CTF Rules 2007/AUSTRAC Easy Reference Guide | Part 6 AML/CTF Rules 2025/AUSTRAC Tranche 2 CDD Guidance | Change |
| Evidence of existence | Yes | Yes | Trust deed or equivalent instrument, will, or letter of administration; Government register (if applicable) | The trust existence is verified with the ABR, ACNC or relevant documentation such as trust deed and other deeds. Usually a combination of sources is used where applicable. | The trust existence is verified with the ABR, ACNC or relevant documentation such as trust deed and other deeds. Usually a combination of sources is used where applicable. | NO |
| Full name of the trust | Yes | Yes | Trust deed and amendments (e.g., deeds of variation); ABN Lookup on Australian Business Register | The trust name is verified with the ABR, ACNC or relevant documentation such as trust deed and other deeds. Usually a combination of sources is used where applicable. | The trust name is verified with the ABR, ACNC or relevant documentation such as trust deed and other deeds. Usually a combination of sources is used where applicable. | NO |
| Trust type or equivalent | Yes | Yes | Trust deed and amendments; Letters/documents from independent professional service providers (lawyer/accountant); ABN Lookup; Foreign registration body information (if applicable) | The trust type is collected/verified with the ABR, ACNC or relevant documentation such as trust deed and other deeds. Usually a combination of sources is used where applicable. | The trust type is collected/verified with the ABR, ACNC or relevant documentation such as trust deed and other deeds. Usually a combination of sources is used where applicable. | NO |
| Business names | Yes | No | All business names are collected from ABR (if applicable) | All business names are collected from ABR (if applicable) | NO | |
| Other names commonly known by | Yes | No | All business/trade names are collected from ABR (if applicable) | All business/trade names are collected from ABR (if applicable) | NO | |
| Unique identifier (ABN if applicable) | Yes | Yes | ABR, SMSF Lookup, or foreign equivalent | The ABN is verified with the ABR and the SMSF lookup where applicable. | The ABN is verified with the ABR and the SMSF lookup where applicable. | NO |
| Principal place of business or operations address | Yes | No | This is the address of the Trustees and is collected directly from the customer, ASIC, or provided documentation. | This is the address of the Trustees and is collected directly from the customer, ASIC, or provided documentation. | NO | |
| Information about powers that bind and govern the trust | Yes | Yes | Trust deed and amendments; Letters/documents from independent professional service providers; Country's laws under which trust was established | Trust deed and other relevant deeds such as Deeds of Variation, Deeds of Amendments, Unit Registers etc. are collected and machine analysed. | Trust deed and other relevant deeds such as Deeds of Variation, Deeds of Amendments, Unit Registers etc. are collected and machine analysed. | NO |
| Individuals responsible for governance and executive decisions | Yes | Yes* | Trust deed; Instrument of appointment; Letters/documents from independent professional service providers | This is obtained from the Trust deed and other relevant deeds such as Deeds of Variation, Deeds of Amendments, Unit Registers etc. which are collected and machine analysed. | This is obtained from the Trust deed and other relevant deeds such as Deeds of Variation, Deeds of Amendments, Unit Registers etc. which are collected and machine analysed. | NO |
| Identity of each beneficiary (or class of beneficiaries if individuals cannot be identified) | Yes | Yes* | Same method as would apply if beneficiary were the customer (individual or entity verification); Trust deed (for class of beneficiaries); Evidence of trust activity. * When there are extremely high numbers of beneficiaries or no named beneficiaries, collect and verify a description of each class of beneficiaries (e.g., "children and descendants," "charitable beneficiaries," "investors") instead of individual identities | This is obtained from the Trust deed and other relevant deeds such as Deeds of Variation, Deeds of Amendments, Unit Registers etc. which are collected and machine analysed. | This is obtained from the Trust deed and other relevant deeds such as Deeds of Variation, Deeds of Amendments, Unit Registers etc. which are collected and machine analysed. | NO |
| Identity of all trustees | Yes | Yes* | Same method as would apply if trustee were the customer (individual or entity verification); Trust deed; Instrument of appointment | At least one trustee is verified with the relevant procedure for an individual or an entity. | All trustees are verified with the relevant procedure for an individual or an entity. | YES |
| Identity of any settlor, appointor, guardian or protector | Yes | Yes* | Individual identity verification guidance; Trust deed; Letters/documents from professional services firms; Copy of trustee resolutions; Memorandum of trust. Verify only individuals who have current control and role (e.g. settlors are not needed in most cases). | The settlor is verified only if the settled sum is $10,000 or more. All other roles (appointor, guardian or protector) are identified and verified. | The settlor is verified only if the settled sum is $10,000 or more, or if they still have an active role in the trust (this is usually not the case). All other roles (appointor, guardian or protector) are identified and verified. | NO |
| Identity of any beneficial owners | Yes | Yes* | Individual identity verification guidance | UBOs are identified and verified | UBOs are identified and verified | SOME |
| Nature of the entity (general commercial activity or sector, and kinds of products and services it offers) | Yes | No | NA | Collected from the customer and/or secondary sources | YES | |
Government Body
| bronID Existing Procedures | bronID New Procedures | |||||
|---|---|---|---|---|---|---|
| Parameter | Collect | Verify | Verification Method | Chapter 4 AML/CTF Rules 2007/AUSTRAC Easy Reference Guide | Part 6 AML/CTF Rules 2025/AUSTRAC Tranche 2 CDD Guidance | Change |
| Evidence of existence | Yes | Yes | Law or executive decision/order establishing the agency; Extract from official government website; ABN Lookup; Government reports and directories | The government body existence is checked by reviewing law or executive decision/order establishing the agency; Extract from official government website; ABN Lookup; Government reports and directories | The government body existence is checked by reviewing law or executive decision/order establishing the agency; Extract from official government website; ABN Lookup; Government reports and directories | NO |
| Full name of the government body | Yes | Yes | Official government website (.gov.au domain); ABN Lookup on Australian Business Register; Legislation or executive decision on official government website; Government reports and directories | The full name is verified with official government website (.gov.au domain); ABN Lookup on Australian Business Register; Legislation or executive decision on official government website; Government reports and directories | The full name is verified with official government website (.gov.au domain); ABN Lookup on Australian Business Register; Legislation or executive decision on official government website; Government reports and directories | NO |
| Other names commonly known by | Yes | No | All business/trade names are collected from ABR (if applicable). International business name registers are used for international government bodies where applicable | All business/trade names are collected from ABR (if applicable). International business name registers are used for international government bodies where applicable | NO | |
| Name of country or part of country under which government body is established | Yes | Yes | Official government website; ABN Lookup; Legislation or executive decision; Government reports and directories | The country or region of establishment is collected from the customer and then verified with official government sources, the ABN lookup or proprietary database | The country or region of establishment is collected from the customer and then verified with official government sources, the ABN lookup or proprietary database | NO |
| Unique identifier (if any has been given) | Yes | No | ABR (if applicable) or foreign equivalent | All business names are collected from ABR (if applicable) or the relevant international business name database. | All business names are collected from ABR (if applicable) or the relevant international business name database. | NO |
| Principal place of business or operations address | Yes | Yes | Official government website; ABN Lookup; Government reports and directories; Reliable and independent publicly available details | The principal place of business is collected from the customer and then cross-referenced with official government website; ABN Lookup; Government reports and directories; Reliable and independent publicly available details | The principal place of business is collected from the customer and then cross-referenced with official government website; ABN Lookup; Government reports and directories; Reliable and independent publicly available details | NO |
| Full name of individuals with primary responsibility for governance and executive decisions | Yes | No | This is not collected. | Collected from the customer or the official government website; Government reports and directories; Reliable and independent publicly available details | YES | |
| Identity of any beneficial owners | Yes | Yes/No* | Official government website (description of individual and role); Instrument of appointment; Publicly available information about governance and control. *Both domestic and foreign government bodies get the beneficial owner exemption if they are low ML/TF risk and enhanced CDD doesn't apply | Identification and verification of beneficial owners is not performed for government bodies | At least one UBO must be identified and verified. | YES |
Additional Requirements (All Entity Types)
| Requirement | Collect | Verify | Verification Method |
|---|---|---|---|
| Identity of any person customer is receiving service on behalf of | Yes | Yes* | Individual identity verification guidance |
| Identity of any person acting on behalf of customer | Yes | Yes* | Individual identity verification guidance |
| Authority of persons acting on behalf of customer | Yes | Yes/No | Information about a representative's authority to act must always be collected, but verification using independent documents (such as power of attorney, agency agreements, trust deeds, or employer confirmations) is only required if the representative's ML/TF risk is not low, doubts exist about the information, enhanced CDD applies, or their authority cannot be established on reasonable grounds from the information collected. |
| Whether any persons are PEPs (politically exposed persons) | Yes | Yes | PEP lists |
| Whether any persons are designated for TFS (targeted financial sanctions) | Yes | Yes | Sanctions lists |
| Nature and purpose of business relationship or occasional transaction | Yes | No | Collected from the customer |
