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 corporate trustee is a company that acts as the trustee of a trust. This article shows how to set up the case so the trust is the root entity, with the trustee company beneath it. You'll work in the Structure tab and the manifest.


In Australia, trustees are commonly companies set up specifically to act as trustee. The trust is often written as "ABC Pty Ltd ATF ABC Trust", where "ATF" means "as trustee for".


Before you start: choose the root entity

The root entity is the entity your organisation is conducting due diligence on.

  • If your organisation acts for the trust, create the case as a Trust, even when the name includes "ATF". The trustee company sits beneath it.
  • If your organisation acts for the trustee company only, create the case as a Private Company.
  • Check the deed before you create the case. Changing the entity type afterwards involves manual rework.


Create the case

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


Collect the trust deed

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

  • The trust 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.


Read the deed with the trust reader

  1. Tick the uploaded documents.
  2. Select Extract documents, and choose the trust type if prompted.
  3. Select Preview extract and check the names and roles against the deed.
  4. Select Unwrap to add the identified individuals to the structure chart.


Add the trustee company to the structure

If the trustee company isn't in the structure after unwrapping, add it manually.

  1. In the Structure tab, select Edit structure.
  2. Select Add entity.
  3. Enter the company's name and registered country, and select Private Company as the entity type.
  4. Set its relationship to the trust as trustee.
  5. Select Add entity.


Unwrap the trustee company

Unwrap the trustee company the same way as any other private company.

  • If you have the company's registration number, unwrap starts automatically.
  • Without it, select Start unwrap manually. If several entities share a similar name, First AML shows suggestions so you can confirm the correct one.

Once unwrapped, the company's directors and shareholders appear in the structure.


Decide who to verify

Who you verify depends on your compliance programme. Individuals commonly considered include:

  • The trustees
  • The appointor
  • The beneficial owners of the trustee company, who are its shareholders

Mark anyone you're not verifying as not needed.


Collect requirements

Go to Quick actions > Send requirements for the individuals you're verifying. Upload supporting documents directly to the case.