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.


A bare trust names its beneficiary directly, which makes it more straightforward to represent in the structure chart than a discretionary trust. This is a common structure in limited recourse borrowing arrangements (LRBAs), where a self-managed super fund is the beneficiary. Always read the trust deed itself to confirm the actual structure; this article shows a typical example, not every possible variation.


Create the case

  1. Start a new case, select Entity, then Bare Trust, and enter the trust's name.
  2. Select Go to case.


Collect the deed

Bare trusts can't be unwrapped automatically. Upload the trust deed directly if you hold it on file, or request it via Quick actions > Send requirements.


Read the deed to identify:

  • The trustee
  • The beneficiary (in an LRBA context, this is commonly a superannuation fund, itself acting through its own trustee)


Build the structure

  1. Select Edit structure > Add entity to add the trustee company, with its registered country.
  2. Add the beneficiary (for example, the superannuation fund) as a controlling party or shareholder, depending on your preference.
  3. Add the superannuation fund's own trustee as a further entity if applicable.


It's common for the same individuals to be involved across the bare trust's trustee and the superfund's trustee, even though the structure looks layered.


Collect requirements

Once the structure reflects the deed, collect the superfund's own governing deed under that entity, and verify the controlling individuals.


For your region:

  • New Zealand: trustees in this structure are commonly a law firm or accounting firm.
  • Australia: trustees are commonly companies set up specifically to act as trustee. This structure (bare trust holding property for an SMSF via an LRBA) is common in Australian real estate transactions.