CDD on companies, trusts, and SMSFs as buyers
How to conduct customer due diligence on corporate buyers, family trusts, unit trusts, and self-managed superannuation funds — including how to identify beneficial owners through complex ownership chains.
Corporate, trust, and SMSF buyers are common in Australian real estate — particularly in premium and investment segments. The AML/CTF Rules 2025 require significantly more verification for these entity types than for individuals, and understanding what you need to collect — and from whom — is one of the most operationally complex parts of the new regime.
The core principle is: look through the entity to the natural persons behind it. A company or trust is a legal construct. Behind it, there are always individuals who ultimately own or control the assets. AUSTRAC requires you to identify those individuals, not just the entity on the contract.
Companies. Confirm the company exists and is registered on the ASIC register — obtain the full company name, ACN, and registered address. Verify the identity of the individual who signs the contract on behalf of the company. Identify any natural person who holds 25% or more of the issued capital and verify their identity as you would any individual buyer. Where a company is itself majority-owned by another company, trace the chain until you reach natural persons at 25% or above.
Discretionary trusts. Obtain a copy of the trust deed or a certified extract. Verify the trustee (or the directors and shareholders of a corporate trustee). Verify the settlor. Where a named beneficiary holds a fixed entitlement of 25% or more, verify them. Where beneficiaries are a class (for example, "the children of the settlor"), document the class description — you are not required to verify every class member individually. Identify and verify any person with power to appoint or remove the trustee.
Unit trusts. Unitholders with 25% or more of total units are beneficial owners who must be verified. Functionally this is the same process as identifying and verifying major shareholders in a company.
SMSFs. Confirm the fund exists and is registered — the ATO's Super Fund Lookup tool verifies an SMSF's ABN and status. Verify each trustee: for individual trustee structures, verify every member (who are also the trustees); for corporate trustee structures, apply the company process to the trustee entity and verify each director individually. Members of an SMSF are its beneficial owners — all members must be verified.
When to apply enhanced CDD. Overseas entities, structures with opaque ownership chains, entities in high-risk jurisdictions, or situations where you cannot trace the chain to natural persons at the 25% threshold are all enhanced CDD triggers. Where you cannot resolve the ownership structure to your satisfaction after reasonable measures, the relationship cannot proceed and a suspicious matter report should be considered.
What to do next: When taking on a corporate or trust customer, request the ASIC extract and trust deed before signing the agency agreement, identify the full beneficial-owner chain, and resolve verification before exchange.