Ultimate beneficial ownership (UBO) checks are part of Annature's Identity verification product. Search for an Australian company, and Annature uses ASIC records to trace its shareholders through every linked company until it reaches the individuals at the top of the structure. Any individual who owns 25% or more, directly or through other companies, is identified as an Ultimate beneficial owner.
Why UBO checks matter
Under the Tranche 2 reforms to the AML/CTF Act, reporting entities such as lawyers, accountants, conveyancers and real estate agents must identify the beneficial owners of customers that are companies, then take reasonable steps to verify who they are. Working this out by hand means ordering an ASIC extract for the company, then another for every company that holds its shares, and adding up percentages across every level. A UBO check does all of this in a single request and gives you a report for your records.
Multi-level ownership checks
Every UBO check is a multi-level ownership check. If a company's shares are held by another company, Annature investigates that company too, and keeps going until it either:
reaches the individuals who own the shares, or
can't go any further. For example, the shareholder is a foreign company, or holds its shares on behalf of someone else, such as a trustee.
Every company investigated along the way is saved in your account as an associated check, so you can open and review each level of the structure. Associated checks aren't charged. Learn more about requested and associated checks.
What's included in a check
Each check gives you:
ASIC extract: company name, ACN, company type, class, status, state of registration, registration date and addresses.
Officeholders: directors, secretaries and other roles held, such as an ultimate holding company.
Ultimate beneficial owners: individuals holding 25% or more, with beneficially held, non-beneficially held and total percentages.
Blocking entities: shareholders holding 25% or more where an individual owner couldn't be found, and the reason why.
Other owners: shareholders below the 25% threshold.
Shares and shareholding: share classes issued, and every shareholder with their class, number of shares and whether they're held beneficially.
Ownership report (PDF): a downloadable report with the full investigation, a relationship diagram and an ABR extract for each company.
Sample reports
These reports are real checks run through Annature. We've removed business and personal addresses from these samples, but they're included in full in the checks you run from your account.
Company | Structure | What it shows |
|---|---|---|
Three individual shareholders | The simplest result: three individuals each beneficially hold 33.33%, so all three are identified as UBOs. | |
Individual behind a holding company | An individual identified as a UBO through one or more linked companies. This is the multi-level check at work. | |
Company holding shares as trustee | 97.5% is held non-beneficially by another company, which is typical of a trust structure. No UBO can be identified from ASIC records, so the company is reported as a blocking entity. | |
Foreign parent company | 100% is held by a UK company, which ASIC records can't trace beyond. The ultimate holding company is listed under officeholders. | |
Jointly held shares | Shares held jointly by two individuals. Each joint holder is treated as owning the whole holding, so totals can add up to more than 100%. |
What happens after a check
A UBO check identifies who the beneficial owners are. To complete your customer due diligence you'll usually also want to:
Verify each UBO's identity using an Identity verification.
Screen each UBO with AML & CTF screening. Screening isn't included in a UBO check.
Look into blocking entities. For example, request the trust deed when shares are held by a trustee.