How do you onboard a company, trust, or partnership under AML/CTF? From 1 July 2026, the answer looks very different from the standard client intake most firms run today. Under the Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) reforms, onboarding a non-individual client becomes a full due diligence exercise.
We unpacked exactly what that means in our recent webinar, AML/CTF Onboarding for Non-individuals, with Mitchell Burge, Head of Revenue and Growth at triSearch, and Ashish Patil, Product Lead for AML/CTF.
Here’s the recap.
Why non-individual onboarding is different
A non-individual client is any entity rather than a person, such as a company, trust, or partnership. Onboarding them means looking past the person giving instructions to the structure and the people behind it.
For an individual client, the process is mostly straightforward. You identify the person, verify their identity, run AML screening where required, and retain the evidence. Once the client is a company, trust, or partnership, the legislation expects you to go deeper. You’re no longer just verifying the person giving instructions. You’re verifying the entity behind that person, and the individuals who ultimately own or control it.
The five onboarding steps
From 1 July, firms need to complete five distinct steps for every non-individual client:
- Establish the legal entity and confirm it exists
- Understand the ownership and control structure
- Identify the ultimate beneficial owners
- Apply AML due diligence to those individuals
- Retain a full, auditable trail of the decision-making
The final step carries more weight than many firms expect. An audit trail involves more than retaining the search results. Firms must also record the reasoning behind the onboarding decision, the individuals identified as owners and controllers, and the checks conducted on each of them.
KYC and KYB: knowing the difference
Two terms come up constantly in this space. KYC, or know your client, focuses on the individual in front of you. KYB, or know your business, focuses on the entity behind them.
If an employee instructs your firm on a transaction, verifying that employee alone doesn’t satisfy your obligations. You also need to establish who owns and controls the company. The same principle applies to trusts and partnerships, where control is often less obvious and spread across multiple parties.
Ultimate beneficial owners
Ultimate beneficial ownership is generating the most questions from firms right now, and it’s where onboarding becomes a true AML exercise.
You need to look through the structure and identify the natural persons who ultimately own or control the entity. In broad terms, that means individuals with 25% or more ownership, or those who exercise effective control even where ownership is less direct. For a company, that may be shareholders. For a trust, it could be trustees, appointors, or beneficiaries. For a partnership, controlling partners or underlying owners.
Once those owners are identified, they become the individuals you screen.
The real challenge is consistency at scale
And the biggest challenge, is for firms to be able to deal with non-individuals. It is not understanding the requirements, but applying them consistently and at scale.
As Mitchell put it, the biggest challenge isn’t understanding the requirements. It’s applying them consistently, across every file and every team, without manually piecing together ASIC searches, spreadsheets, notes, and separate reports to work out who needs checking.
That’s the gap the triSearch Compliance Centre is built to close. Rather than treating entity verification, beneficial ownership, and AML screening as separate tasks, it brings them into one guided onboarding journey, with all evidence stored in a single auditable record.
Up next: AML/CTF Customer Due Diligence Workflow webinar
Onboarding is the first piece. Our next session turns to customer due diligence (CDD), one of the most frequently misapplied parts of the AML/CTF framework, where firms often over-collect, under-document, or apply the wrong level of scrutiny for a client’s risk profile.
It breaks down what a compliant CDD workflow looks like, from first contact through to ongoing monitoring, and shows how the Compliance Centre supports each stage.
Join us on Tuesday 16 June 2026 at 12pm AEST, online via Zoom.
Missed the session?
A full recording of the webinar will be available on the triSearch website.
For a closer look at how this would work in your firm, you can book a personalised demonstration with a triSearch representative here.
