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A KYB failed to identify known UBOs. What's the workaround?

Use manual UBO declaration: the customer enters beneficial-owner details directly via the platform and confirms them against alternative sources where possible.

The fallback is manual UBO declaration - the customer enters the beneficial-owner details directly via the platform, and easyAML's data team confirms them against alternative sources where possible. The CDD record is preserved with the same audit-trail standard as an automated unwrap.

Why an automated unwrap might miss a known UBO:

  • ASIC data is stale. A recent share transfer or director change hasn't yet been reflected in ASIC - the customer should lodge an ASIC Form 484 to bring the public register current. easyAML re-reads from authoritative data, so updating ASIC is the cleanest fix.
  • A trust sits in the middle of the structure. Trusts aren't externally registered; the unwrap pauses at the trust layer and asks for the deed. (See "What happens during 'unwrap' when a corporate shareholder turns out to be a trust?" in Section 3.)
  • An offshore parent is involved. Foreign corporate registers don’t always provide live data connections like the standard ASIC integration; Tier 2 / Tier 3 KYB pricing applies for these (see Section 8).
  • Nominee or custodian arrangements. ASIC shows "beneficially held = false" - the named shareholder isn't the real owner. Documentation of the underlying arrangement is needed.

What the manual fallback looks like in the platform:

  1. The customer is prompted via the platform to confirm the UBOs - name, DOB, ownership %, role (director / shareholder / appointor / trustee).
  2. Verify the supplied data against alternative sources where available (ASIC historical extracts, supplied documents).
  3. The KYB record is completed with the manually entered UBOs flagged in the audit log.
  4. KYC links go out to each identified controller as normal.

Any KYB unwrap issue is also flagged to the data team for diagnosis - repeated mismatches against a known structure get product-team attention to improve the automated path.

The reporting entity remains responsible for the integrity of the final CDD record - the manual fallback is a workflow tool, not a downgrade of the standard. See AUSTRAC's Trust and corporate services designated services page.

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