The Act requires us to conduct Customer Due Diligence (CDD) on:
- our client;
- any person acting on behalf of our client; and
- If our client is acting on behalf of someone else, the person on whose behalf the transaction is being conducted.
If our client is a company trust, partnership or other business arrangement (we will call this an entity), then we also need to conduct CDD on any person who:
- owns more than 25% of the entity either directly or indirectly;
- controls more than 25% of voting rights;
- can exercise effective control over the entity such as directors, senior executives or people holding certain management positions; and
- is acting on behalf of the entity such as the employee instructing us or an external property manager who can instruct us on leasing matters.
We may also ask about the purpose of the business our client is undertaking and for information about the source of their wealth or the source of funds applied to a transaction or deposit into our trust account.