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When our customer is an SMSF, who do we need to KYC?

SMSFs are legally trusts: KYC each member-trustee for individual-trustee SMSFs.

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 (do KYB to verify it exists via ASIC)  
  • Each director of that company.
  • Each UBO shareholder who owns/control 25% of trustee company
  • Each fund member.
  • PEP and sanctions screening on all identified individuals and company.

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?
Does AUSTRAC require settlors to be identified and KYC as part of a trust CDD?

See AUSTRAC's Initial CDD for a trust page.

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