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.


When a company's shares are held through other companies or trusts, First AML's unwrap feature follows that chain and calculates each party's indirect ownership of your customer, so you can identify who meets your beneficial ownership threshold even when they don't directly hold shares.


How indirect ownership is calculated

When you view a shareholder in the structure chart, two figures are shown:

  1. Grey figure: this entity's direct shareholding in the entity immediately above it.
  2. Red figure: this entity's overall shareholding in the entity at the top of the structure (your customer).

An entity only needs to be verified as a beneficial owner if its red figure meets your compliance program's threshold (commonly 25%, in line with AUSTRAC's guidance), even if its direct holding in an intermediate company is much higher.


Reading the company extract

Where a shareholder is shown as holding shares "beneficially held: false" in a company extract, this typically indicates a trust holds those shares, with a company or individual acting as trustee. First AML reflects this automatically in the structure chart once unwrapped, showing the trust and its trustee.


Working through the manifest

Once the structure is built out:

  • Entities below your threshold are marked as not needed automatically.
  • Entities and individuals above it need supporting documents, for example a trust deed for a trust holding shares, or identity verification for an individual beneficial owner.
  • You may also choose to verify individuals who control an intermediate company in the chain, for example a sole director and shareholder, depending on your compliance program.


Use the key at the top of the structure chart to understand what each tag (such as UBO) refers to.