When a company is owned by another company, how far do we need to trace?
Trace until you reach the natural persons at the end of the ownership chain; AUSTRAC expects ultimate beneficial owners to be identified.
You trace until you reach the natural persons(individuals) at the end of the chain. Every entity in the chain is a step, not a destination. If your customer is owned 100% by a holding company, which is owned 60% by a family trust, you need to identify:
- The holding company (verify it exists).
- The family trust (verify it exists and capture trustees, appointor, settlor, beneficiaries).
- The natural persons who control the trust and would therefore indirectly control your customer.
AUSTRAC explicitly expects you to keep records that show each link in the chain. Current and historic ASIC searches are the standard evidence for company chains. See AUSTRAC's Determining ownership and control structures (Reform) page.
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