Why does the system show 'beneficially held = false' for a shareholder?
Because ASIC's share register records that the shareholder is not the true economic owner of those shares (typically holding as trustee or nominee), so the platform flags a likely trust layer.
This comes directly from ASIC. When a company files a share register update, it specifies for each shareholding whether the shares are held beneficially (the shareholder is the true economic owner) or non-beneficially (the shareholder is holding the shares for someone else, typically as trustee, nominee or custodian).
When easyAML sees beneficiallyHeld = false on a shareholding:
- It treats the named shareholder as not the ultimate owner of those shares.
- It flags the entity as having a likely trust, nominee or custodian arrangement sitting behind it.
- It pauses the KYB unwrap at that layer and requests documentation - usually the trust deed plus details of trustees, appointor and beneficiaries.
Why this matters for CDD: AUSTRAC's beneficial ownership rules look through legal title to the natural persons who ultimately own, benefit or control the customer. A "beneficially held \= false" flag is the platform's way of saying we haven't yet reached the ultimate owner - keep unwrapping. Once the trust deed and controlling persons are loaded, the structure is fully verified.
If you believe the ASIC flag is wrong (e.g. the share register hasn't been updated to reflect a transfer), the customer should update the ASIC record first - easyAML re-runs from authoritative data, so a manual override would defeat the audit trail.
See AUSTRAC's Trust and corporate services designated services.
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