Step 3 — Verification of identity (VOI)
Before issuing identity checks, you must establish the Ultimate Beneficial Owner (UBO) structure — the natural persons who ultimately own or control the entity.
Establishing the UBO structure
A UBO is any individual who:
- Holds 25% or more of the shares, units, or equivalent interest, or
- Holds a share class or other arrangement that confers elevated voting rights, even if their economic interest is below the 25% threshold.
Where a company, trust, or other entity sits within the ownership chain, trace through it until you reach natural persons. Record the full chain in SBOS before issuing any VOI requests.
Add each UBO as a contact and link them to the entity on the CDD run before proceeding.
Process Note
Generally, it is best practice to establish the UBOs before completing the CDD.
Issuing VOI checks
A VOI check must be issued to each UBO individually. SBOS supports two methods.
- Manual: Complete the VOI check manually and record the details (document type, number, and expiry) directly in the CDD run. Keep certified copies in the matter file.
- Third-party service: Send an automated request via the connected VOI provider (where enabled). Results are imported and attached to the run automatically.
Document requirements
Document requirements for VOI differ depending on the type of services. For conveyancing services two documents are required, a government-issued photo ID (such as a passport or driver's licence) and a secondary document (such as a Medicare card or utility bill). All other standard designated services only require the government issued photo ID.
Completing VOI in SBOS
- Within the CDD run, open the UBO / VOI section.
- Add or confirm the UBO individuals linked to this run.
- For each UBO, select Issue VOI check and choose manual or third-party.
- Record the document type, document number, and expiry date — or attach the third-party provider result.
- Mark each UBO's VOI status as Cleared once verified.
- Advance to Step 4 — PEP and sanctions screening once all UBOs are cleared.
Manual VOI records
SBOS stores the metadata (document type, number, expiry). Keep the physical or scanned copies of the documents in the matter file as your evidentiary record.
Expired documents
VOI checks based on expired identity documents are non-compliant. If a document is close to expiry, request a current document before clearing the check.
Reusing VOI results across matters
Where the same client has multiple matters, a previously completed and in-date VOI result can be reused — you do not need to re-issue identity checks unless the re-verification schedule has been triggered. A new disclosure form and risk assessment are still required per matter.