Do minors who are beneficiaries of a trust need to be KYC'd?
No, full KYC on beneficiaries who are under 18 is not required because they cannot exert control over the trust and cannot reasonably be verified without consent capacity.
Full KYC on beneficiaries who are minors isn't required, and AUSTRAC doesn't expect reporting entities to perform identity verification on people who can’t exert control over trust and who can't reasonably be verified (no driver's licence, no passport unless travelling, no consent capacity).
The same rule applies to unnamed classes of beneficiaries - for example, "the children and remoter issue of John Smith" or "the descendants of the settlor". The class is identified at the trust level (you record that such a class exists in the deed); individual class members aren't separately verified.
What you do need to capture:
- The trustee, appointor (or principal/guardian), and settlor - all real, identifiable adults.
- Any named adult beneficiary with substantial entitlement, especially in discretionary trusts where they could in principle receive the whole benefit.
- If the trust is directly party to a transaction and a minor stands to receive a substantial distribution, document the minor's existence on file (name, DOB) without running a full VOI.
A minor turning 18 during the customer relationship doesn't automatically trigger a VOI - but if the relationship significantly changes or a new designated service is provided to them in their own right, initial CDD applies at that point.
Related articles
- What does the KYB unit price include?
- What's the difference between CDD, KYC and KYB - and when does each apply?
- Does AUSTRAC require settlors to be identified and KYC as part of a trust CDD?
- When the customer is a trust, do beneficiaries need to be identified and verified? How does this differ by trust type?
- For company/trust onboarding where the trust deed isn't yet in easyAML, what should the user do?