This guide will assist you in using the bronID identity verification portal for identity verification and risk assessment services to determine, with reasonable satisfaction, that the target private company is who they claim to be for the purpose of AML/CTF compliance.
Where possible bronID will use the Simplified Company Verification
In all other cases, a standard verification procedure is used.
Step 1: Collection
During the initial customer onboarding process collect the following KYC information about a customer who is a company:
The full name of the company as registered by the relevant national regulator.
The full address of the company’s registered office.
The full address of the company’s principal place of business, if any.
The Company Number issued to the company;
The name of each director of the company;
The country in which the company was formed, incorporated or registered;
Collect information on the Ultimate Beneficial Owners
For foreign companies registered in Australia:
The ARBN issued to the company;
Step 2: Verification
The bronID verification portal primarily uses the ‘ready-reckoner procedure’ where the ML/TF risk is medium or lower, to verify, at a minimum, the following KYC information about the customer:
Verify and recorded the full name, entity type and the registration/identification number(s) of the entity, with the relevant registered database(s). (For Australia: ASIC, ATO)
Recorded the country in which the entity was formed, incorporated or registered, the full address of the registered office and principal place of business.
Recorded and confirmed the full name of each director of the entity with the relevant regulators registered database and/or official entity documentation.
Performed electronic-based safe harbour verification for all beneficial owners (individuals with 25% or greater ownership)
Check UBOs against watchlists and sanctions to determine whether any are PEPs
Step 3: Interpreting your Results
With bronID, a Private Company is Verified when;
- The company exists;
- The company’s name, address and company number is matched with at least one reliable database;
- The company directors are identified by querying at least one reliable database;
- The company ownership structure is identified and verified until at least one of the following requirement is satisfied:
- The owner (25% ownership or higher) of the organisation in the ownership structure is a natural person; or
- The owner (25% ownership or higher) of the organisation in the ownership structure is an organisation that can be verified with a Simplified Verification Procedure.
When 1. and 2. return negative results, then the verification status will be set to “Not Verified”.
When 3. to 5. cannot be completed, then the verification status will be set to “Info”.
- See Entity Verification Status Guide for guidance on responding to these statuses and how to achieve a verified result.
Step 4: Keeping Records
Upon carrying out the identity verification procedure, a record of the procedure and the identifying information produced to perform the verification is stored in the bronID portal, specifically the Results menu.
We advise that these records also be stored in your own backup storage.
Both the procedure data and identifying information are to be stored for the duration of the relationship with that customer, as well as for an additional seven years after the provision of any designated service ceases.
Step 5: Provision of Service
Only once you have verified that an entity customer who is a private company is who they claim to be by following the steps outlined and verified the ultimate beneficial owners, should you provide the designated service.