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.


Unit trusts are more complex than family or discretionary trusts because ownership is held in units rather than a simple list of beneficiaries. This article walks through building out a unit trust structure and identifying beneficial owners from a unit register.


Create the case

  1. Start a new case, select Entity, then Unit Trust (this is a separate entity type to a standard trust).
  2. Enter the trust's name and add a case contact.
  3. Select Go to case.


Collect the documents

Unit trusts can't be unwrapped automatically. The manifest will typically request:

  • A trust deed
  • A deed of amendments, if applicable
  • A unit register

The unit register isn't always mandatory, but it's good practice to collect one, as it confirms who currently holds units in the trust.


Extract and review

You can run the trust reader on the trust deed, but it does not currently extract unit holder information from the deed itself; this is being looked into. 


In the meantime, read the unit register directly to identify unit holders. A unit register works similarly to a shareholder register: it lists each unit holder and their percentage holding.


Build out the structure

Once you know who holds units above your beneficial ownership threshold, add them to the structure chart:

  1. Select Edit structure > Add entity.
  2. Enter each unit holder as an entity (for example, a trust or company), with its registered country and unit holding as a shareholding percentage.
  3. If a unit holder is itself a trust with a corporate trustee, add the trustee company too and mark the relationship as trustee.
  4. Unwrap any corporate entities to identify their directors and shareholders.


Decide who to verify

Once the structure reflects the unit register, you'll typically be collecting trust deeds for each unit-holding trust above your threshold, and verifying the individuals who control the corporate trustees.


For your region:

  • New Zealand: trustees of the unit-holding trusts are commonly a law firm or accounting firm.
  • Australia: trustees are commonly companies set up specifically to act as trustee.