When our customer is a government body, who do we need to KYC?
Verify the body itself (name, jurisdiction, address) and apply the deemed-compliance pathway with a documented ML/TF risk assessment; individual signatories are identified case by case.
A government body includes the government of a country (or part of one) and any agency or authority of such a government. Examples: the Commonwealth Department of Defence, a state revenue office, a local council.
Information to collect about the government body
- Full name of the body
- Jurisdiction (Commonwealth, state/territory, local, or foreign)
- Principal place of business or address of the relevant office
- Documented ML/TF risk assessment supporting the deemed-compliance pathway, if applicable
Individuals to identify (KYC)
- The representative engaging with you and their authority to act. Authority is usually evidenced through a delegation instrument, employment letterhead, or formal agency authority.
- Beneficial owners are generally deemed established if the body's ML/TF risk is low - record the risk assessment that supports this.
- PEP screening on the representative. Senior government officeholders often meet the definition of a domestic PEP.
You only need to verify the specific officer acting on your matter, not every officer of the body. For more on the deemed compliance pathway available for government bodies, see "Do we need to identify beneficial owners behind a publicly listed company or government body customer?"
See AUSTRAC's Initial CDD for a government body page.
Related articles
- Glossary: Key Terms & Definitions
- What's the difference between CDD, KYC and KYB - and when does each apply?
- Who or what is a Politically Exposed Person (PEP)?
- Do we need to identify beneficial owners behind a publicly listed company or government body customer?
- When our customer is an Australian Pty Ltd company, who do we need to KYC?