TABLE OF CONTENTS


This article outlines one approach to configuring this in First AML for Australian customers. It is intended as general guidance rather than prescriptive instructions.

The structure of your cases and the individuals you verify depend on your organisation's compliance programme and the legislation applicable in your jurisdiction.


Self-managed superannuation funds (SMSFs) can't be automatically unwrapped from a public register, because there's no equivalent database First AML can pull structure data from. You'll need to collect the fund's governing documents directly.


Before you start

You can check whether a fund is complying or non-complying using the Super Fund Lookup website (superfundlookup.gov.au), but this doesn't replace collecting the deed itself.


Create the case

  1. Start a new case, select Entity, then Superannuation Fund.
  2. Enter the fund's name and any individuals you already know are involved.
  3. Select Go to case.


Collect the deed

Open the manifest to see what's needed. First AML will typically request:

  • The Superfund deed
  • A deed of amendments, if applicable

Go to Quick actions > Send requirements to request these, or upload them directly if you already hold them on file. If there's no deed of amendments, mark this as complete once confirmed.


Use the trust reader

Once the deed (and any amendments) are uploaded, you may choose to use the trust reader to extract the trustees and members automatically:

  1. Tick the uploaded documents.
  2. Select Extract documents and wait for the extract to complete.
  3. Select Preview extract to review what's been identified.
  4. Select Unwrap to add the identified individuals to the structure chart with the appropriate tags.


Identify who to verify

The trust reader identifies the controlling individuals of the fund, commonly the members, who are usually also the trustees in an SMSF. Send identity verification requests to these individuals via Quick actions > Send requirements.

Where a fund uses a corporate trustee rather than individual trustees:

  1. Unwrap that trustee company the same way as any other private company.
  2. Verify its beneficial owners, commonly the same individuals already identified as members of the fund.

For your region:

  • New Zealand: the trustee is commonly a law firm or accounting firm.
  • Australia: the trustee is commonly a company set up specifically to act as trustee (for example, "Smith Pty Ltd").