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4 | Anti-money laundering information
Step 1: Customer due diligence (CDD)
A property will be owned by: individual(s) – trust(s) – For registered proprietors in the name of a Trust:
company(ies) – other entities Ask the owners to provide a copy of the trust deed
Client due diligence is where the licensee is required and establish the names of the trustees
to identify who the “beneficial owner(s)/real person(s) • Commence the personal identification/
are� The ‘beneficial owner(s)/real person(s) are verification process on each of those persons
not just the registered proprietors shown on the For registered proprietors in the name of a
Certificate of Title� For AML purposes they are the company:
entities who have an interest in the property�
• Ask the owners to provide a copy of the
When the licensee is initially contacted by the company registration certificate and establish
prospective vendor they should: who is entitled to sign the documents and who
• Obtain a Certificate of Title for the property to has a 25% or greater ownership in the company
establish who are the registered proprietors on • Commence the personal identification/
the title document� verification process on each of those persons
For registered proprietors in the name of a club
or society; a co-operative; a sole trader and/or
If the registered proprietors are individuals in partnership:
their own right the licensee must establish
from the vendor if there is also a family • Ask the owners to provide a copy of the deed/
trust involved in the property� The family registration certificate and establish who has the
trust might not be shown as a registered authority to sign the documents
proprietor on the title but they are an entity • Commence the personal identification/
that has an interest in the property� verification process on each of those persons
For individual registered proprietors:
• Commence the personal identification/
verification process on each individual registered
proprietor
For individual registered proprietors who have a
family trust involved in the property:
• Ask the individual owners to provide a copy
of the family trust deed or if there is no trust
deed available ask for the contact details
of the other trustees
• Commence the personal identification/
verification process on each “beneficial owner/
real person”
BFT015 DEC18