When our customer is an Australian public company, who do we need to KYC?
ASX or other prescribed-exchange-listed companies benefit from a simplified beneficial-ownership approach because continuous disclosure rules make ownership public.
This entry covers ASX-listed (or other prescribed exchange-listed) Australian public companies. Listed public companies are subject to continuous disclosure rules, which means their ownership is already in the public domain. AUSTRAC recognises this and allows a simplified approach to beneficial ownership in most circumstances.
Information to collect about the company
- Full registered name (as shown on ASIC)
- ACN
- Type of company (public, listed)
- Prescribed exchange on which the company is listed (ASX or equivalent)
- Registered office address
Individuals to identify (KYC)
- The representative engaging with you and their authority to act.
- Beneficial owners - the simplified approach typically applies. Continuous disclosure obligations through the exchange already provide ownership transparency, so you generally don't need to identify significant individual shareholders.
- PEP and sanctions screening on the representative.
The simplified approach reduces but doesn't eliminate beneficial owner obligations - document why you applied the simplification based on your ML/TF risk assessment. For more on the deemed compliance pathway available for listed public companies, see "Do we need to identify beneficial owners behind a publicly listed company or government body customer?" in Section 7. See AUSTRAC's Initial CDD for a body corporate, partnership or unincorporated association (Reform) page.
Related articles
- Glossary: Key Terms & Definitions
- What's the difference between CDD, KYC and KYB - and when does each apply?
- 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?
- When our customer is an SMSF, who do we need to KYC?