When our customer is an SMSF, who do we need to KYC?
SMSFs are legally trusts: KYC each member-trustee for individual-trustee SMSFs, or KYB the corporate trustee plus KYC each director.
A self-managed super fund is legally a trust, so the trust rules apply. The structure (individual trustees vs corporate trustee) determines whose ID you collect.
Information to collect about the fund
- Full name of the fund
- ABN
- Trust deed
- Trustee structure (individual trustees or corporate trustee)
- Register of fund members
Individuals to identify (KYC) - individual-trustee SMSF (most common)
- Each member-trustee. Members of an SMSF are almost always also trustees, so the same people are captured under both roles.
- PEP and sanctions screening on all identified individuals.
Individuals to identify (KYC) - corporate-trustee SMSF
- The trustee company (verify it exists via ASIC) AND each director of that company.
- Each fund member.
- PEP and sanctions screening on all identified individuals.
For the broader trust framework that an SMSF inherits - beneficiary identification, settlor analysis, treatment by trust type - see "When a discretionary trust is involved, who needs to be KYC'd?", "When the customer is a trust, do beneficiaries need to be identified and verified? How does this differ by trust type?", and "Does AUSTRAC require settlors to be identified and KYC as part of a trust CDD?" elsewhere in this section. See AUSTRAC's Initial CDD for a trust (Reform) page.
Related articles
- What does the KYB unit price include?
- Glossary: Key Terms & Definitions
- 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?