From 1 July, AML/CTF obligations for non-individual clients in Australia significantly change how firms onboard companies, trusts and partnerships. Instead of simply verifying an instructing person, firms must now identify who ultimately owns or controls the entity and apply due diligence at that level.
This shift moves onboarding from basic client intake to a structured Know Your Business (KYB) and Ultimate Beneficial Ownership (UBO) compliance process.
Under the updated AML/CTF framework, firms can no longer rely on traditional onboarding methods such as collecting basic company details or verifying a representative.
For non-individual clients, firms must:
This applies across all designated services where firms are required to comply with AML/CTF obligations.
KYB, or Know Your Business, is the process of understanding the entity behind a transaction.
Unlike KYC (Know Your Client), which focuses on individuals, KYB requires firms to assess:
KYB is now a core requirement for AML/CTF onboarding of companies, trusts and partnerships.
A UBO is the natural person who ultimately owns or controls a legal entity.
In most cases, this includes individuals who:
Once identified, UBOs must undergo AML/CTF checks such as:
Understanding UBOs is central to meeting AML/CTF compliance obligations.
Many firms currently manage non-individual onboarding using manual or disconnected processes, including:
This creates operational inefficiencies and makes it difficult to maintain a consistent audit trail.
The key challenge is not understanding AML/CTF requirements but applying them consistently at scale.
Modern onboarding workflows are shifting towards integrated compliance processes that bring KYB, UBO identification and AML/CTF checks into a single system.
A structured workflow typically includes:
Clients complete a structured KYB form capturing:
Firms conduct searches to:
Some platforms also support international UBO identification for overseas entities.
Once individuals are identified, firms apply AML/CTF checks including:
These checks apply to both representatives and UBOs.
Each matter is assessed based on risk factors such as:
The outcome determines whether the matter is low, medium or high risk and whether escalation is required.
At completion, firms generate a consolidated AML/CTF report that includes:
This creates a complete audit trail for compliance and regulatory review.
AML/CTF onboarding must be completed before or at the point a designated service is provided.
In practice, this means firms should ensure:
AML/CTF Tranche 2 reforms fundamentally change how firms onboard non-individual clients.
The focus is no longer just on verifying an instructing person, but on understanding the full ownership and control structure behind every entity.
For firms, this means:
Firms that move early to standardise onboarding processes will be better positioned to manage compliance efficiently and at scale once obligations commence.
As AML/CTF obligations expand from 1 July, firms need onboarding processes that are both compliant and operationally efficient. Managing KYB, UBO identification, AML/CTF screening and audit records manually can quickly become complex, particularly when onboarding non-individual clients at scale.
InfoTrack helps firms streamline AML/CTF onboarding by bringing key compliance steps into a single workflow. Through InfoTrack’s all-inclusive Compliance Centre, firms can collect KYB information, verify entities, identify UBOs, complete AML/CTF checks including PEPs, sanctions and adverse media screening, and maintain a consolidated audit-ready compliance record.
By integrating onboarding and compliance into one process, firms can reduce duplication, improve consistency across teams and prepare for Tranche 2 obligations with greater confidence.
To learn more about how InfoTrack can support your AML/CTF onboarding workflows, visit our website.
