Step 1 — Client disclosure form

The first step in every CDD run is completing the relevant client disclosure form for the entity type being onboarded. The form collects the information required before a risk assessment can proceed.

Completing the form in SBOS

1. Open the Matter and switch to the AML/CTF tab.
2. Select New CDD run.
3. Confirm which entity the CDD is to be run on. The CDD needs to be run on either the organisation or the contact associated with the matter, but not both. Please select the entity that the work most closely relates to.

• If the CDD is to be run on an organisation, you will be prompted to determine the Ultimate Business Owners before completing the CDD. This can be achieved by clicking the Derive UBO's link against the Beneficial Owners section.
• Here you will either need to select the owners already associated with the organisation (if the organisation has been set up for a previous matter), or you can click Open Relationships to add those details.
• On the organisation's relationship page, you can then either manually add the relationships, or Order an extract from ASIC, or upload and scrape an ASIC PDF you already have on file. Once the relevant entities and owners have been added you can then return to the Matter AML/CTF page to select the UBOs

4. Start the client disclosure form and fill out all details you already know about the client.
5. Send the link to the client to procure the remaining information, including supporting documentation.
6. Once complete, proceed to Step 2 — Internal risk assessment.

Incomplete forms

You cannot progress to the risk assessment step until all mandatory fields are saved.

Required information for CDD

When you initiate a new CDD run, and confirming the entity, the CDD form can be filled out. The field set displayed changes based on your selection.

Individuals and sole traders

• Full name: as it appears on government-issued ID
• Date of birth
• Residential address
• Country of residence
• Occupation
• Tax File Number (TFN): where applicable
• Details of service requested
• Transaction profile: see Transaction profile fields below
• PEP declaration: Politically Exposed Person. Covers the individual, their family members, and close business associates

Body corporates and partnerships

• Entity type: e.g. proprietary company, public company, partnership
• Legal name
• Trading / business name: if different from legal name
• Jurisdiction of incorporation or establishment
• Principal place of business
• Registered office address
• Nature of the organisation's business or operations
• Governing powers: e.g. partnership agreement, company constitution

Trusts

• Kind of trust: e.g. discretionary, unit, testamentary
• Full name of trust: as it appears on the trust deed |
• Jurisdiction of establishment
• Principal place of business

Government bodies

• Name of the body
• Jurisdiction
• Establishing legislation or executive instrument: e.g. Migration Act 1958 (Cth)
• Nature of the body

Fields required for all entities

Regardless of entity type, the following must also be collected.

• Services being requested
• Ownership and control structure: can be described or a diagram can be attached
• Government body or government-controlled?
• Subject to regulatory oversight?: e.g. APRA, ASIC
• Strata or community title corporation/association?
• Publicly listed?
• Transaction profile: see Transaction profile fields below

Transaction profile fields

The transaction profile is collected for all entity types. Each affirmative answer flags the matter for closer review.

• Does the transaction involve physical cash or virtual assets (e.g. cryptocurrency)?
• Is the transaction value greater than AUD 1 million?
• Does the transaction involve another country?

See also

• AML/CTF overview
• Step 2 — Internal risk assessment
• Clients
• Contacts