Non-Individual Customer Due Diligence
Non-individual customer due diligence end to end. Australian business structures and which one you are actually looking at; ownership against control; company CDD including tracing indirect ownership; partnerships, associations and trusts in depth; then layered ownership, nominee structures, foreign entities and ECDD triggers.
5 modules · 73 lessons · 389 min
$99
12 months’ access from purchase · ex GST
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- On-demand, watch on any device
- Branded completion certificate
- Knowledge assessment
General information only, current as at 1 September 2026. Not legal, financial or regulatory advice. Laws and AUSTRAC guidance change. Use at your own discretion. See our content disclaimer.
About this course
A company, a partnership, an association and a trust are four different customers with four different minimums, and the commonest error is treating the entity in front of you as the one you know best. This course works through each in turn, then through the structures that combine them. Five modules. The first covers Australian business structures and which one you are actually looking at, ownership against control, beneficially and non-beneficially held holdings, and company CDD end to end including tracing indirect ownership through corporate shareholders. The second establishes what the customer actually is, which is the question the rest of the course depends on. The third covers partnerships and limited partnerships, and incorporated and unincorporated associations. The fourth covers trusts in depth, where the reform matters most: the trust is the customer, not the trustee, and the settlor, appointor, guardian and protector are all part of the minimum. The fifth covers what happens when structures layer: multiple ownership paths, nominee arrangements, the listed public company exception and the condition attached to it, foreign entities and foreign documents, ECDD triggers, and end-to-end cases including one that cannot be completed. The course is written for the analyst doing the tracing, and for anyone reviewing that work. It assumes familiarity with individual CDD rather than legal training.
Curriculum
Business Structures, Ownership and Control
- What Non-Individual CDD IsPreview4 min
- The Regulatory Framework and the First Question5 min
- Sole Traders and Companies6 min
- Ownership, Control, and Tracing the Chain5 min
- BH and NBH, and Partnerships5 min
- Limited Partnerships, Associations and Trusts5 min
- Foreign Entities and the Collection Versus Verification Table5 min
- What Documents Actually Tell You, and Two Discrepancies5 min
- Ownership Discrepancies and Non-Individual Risk5 min
- Structure, Purpose and Authority in Practice6 min
- Bring It Together, and Ten Common Mistakes6 min
- Analyst Tips, and What Simplified CDD Actually Means6 min
- What Simplified CDD Still Requires, and Where It Stops6 min
- Simplified CDD, A Worked Example6 min
- Simplified CDD's Limit, and the Module Close6 min
Identifying the Customer
- What Is the Customer?7 min
- Accepted Sources, What Does Each One Actually Prove?3 min
- Simple Ownership and the Beneficial Ownership Approach4 min
- Tracing Through a Corporate Shareholder4 min
- Direct and Indirect Ownership, Share Classes, and BH Shareholdings4 min
- NBH Holdings, Directors, and Control Without Large Ownership5 min
- What if No Beneficial Owner Can Be Established?8 min
- Persons Acting on Behalf and Online Onboarding Discrepancies5 min
- Discrepancies in Practice, Status, Naming and Purpose5 min
- High Risk Company Factors5 min
- Company Discrepancies in the Round4 min
- Case Study, Southern Cross Equipment6 min
- Common Mistakes, Analyst Tips and Module Summary6 min
Partnerships and Associations
- Regulatory Foundation and What a Partnership Is6 min
- Collection, Verification and the Partnership Agreement6 min
- Current Partners, Authority and the Limited Partnership6 min
- Layered Partners, Corporate Partners and Incorporated Associations6 min
- Associations, What to Collect and Two Authority Cases6 min
- Unincorporated Associations, Charities and Online Onboarding6 min
- Authority, Purpose and Risk for Partnerships and Associations7 min
- When the Numbers and the Registers Do Not Agree5 min
- End to End Partnership Case5 min
- Common Mistakes, Analyst Tips, and What a Government Body Is5 min
- What Must Be Collected for a Government Body5 min
- The Government-Body Deeming Provision4 min
- Government-Owned and Government-Controlled Companies6 min
- Module 3 Close, Partnerships, Associations and Government Bodies6 min
Trusts: The Trust Is the Customer
- Important Reform Change: The Trust Is the Customer3 min
- Regulatory Foundation7 min
- What Is a Trust?4 min
- Trust CDD, Who Are the Key Persons?7 min
- The Schedule Is Not the Whole File6 min
- Appointors, Protectors and the Power Behind the Trustee4 min
- Beneficiaries, Named, Classed, Fixed and Unitised5 min
- Settlors and Persons Acting on Behalf of the Trust5 min
- Trust Deed Anatomy and Online Onboarding Discrepancies6 min
- Missing Variations, Trust Purpose and Trust Risk5 min
- High-Risk Trusts and Discrepancy Management6 min
- End-to-End Trust Case and a Good CDD Record5 min
- Common Mistakes, Analyst Tips, and What a Bare Trust Is5 min
- Why the Distinction Matters, and Who Should Be Identified5 min
- How the Legal Requirements Apply, and What Documents to Review6 min
- Finishing the Bare Trust Examples, and Module Summary6 min
Beneficial Ownership and Complex Structures
- Beneficial Ownership, Final Regulatory Reminder4 min
- Complex Ownership and the Semi-Real Company Case6 min
- Multiple Ownership Paths, Nominee and NBH Structures, and Trusts5 min
- Listed Public Companies, an Important Exception4 min
- What If Beneficial Owners Cannot Be Established?5 min
- Foreign Company, Collection and Verification5 min
- Translation, Discrepancy and Geographic Risk4 min
- ECDD, When It Must Be Considered4 min
- High Risk, ECDD and Prohibited Customers6 min
- Foreign Entities Online, and a Registry Discrepancy5 min
- A Company Inside a Trust, and Acting on Behalf of a Foreign Customer6 min
- Public Company Behind a Private Branch, and the Outcomes of Non-Individual CDD5 min
- End-to-End Case, Foreign Layered Company; End-to-End Case, High Risk and ECDD Trigger6 min
- End-to-End Case, CDD Cannot Yet Be Completed; End-to-End Case, Complex but Explainable; Good Complex CDD Record6 min
- Common Mistakes, Analyst Tips and Module Summary7 min