Most CDD templates come in three flavours: individual, company, trust. Then a file lands that is none of them. Two GPs who have practised as a partnership since 1998. A husband, wife and adult son farming under a partnership agreement. The local tennis club, run by a committee, selling its old clubhouse.
AUSTRAC groups these clients with companies in one guide, initial CDD for a body corporate, partnership or unincorporated association (opens in a new tab) (last updated 25 August 2026). Since 1 July you have been operating under the rules it explains. This post walks through what it asks for when the client is a partnership or an association, because that is where the company habits stop working.
Why AUSTRAC treats these clients seriously
AUSTRAC's starting point is blunt: bodies corporate, partnerships and unincorporated associations are used for a range of legitimate purposes, and they are also commonly used by money launderers to disguise the illicit origins of proceeds and the individuals who control them. Its National Money Laundering Risk Assessment 2024 rated legal structures and bodies corporate as a high money laundering risk (AUSTRAC, node 1308 (opens in a new tab)).
The same page gives you the counterweight in the next breath: a nationally high risk structure does not make every such customer high risk for your business. The GP partnership can come out low risk. You only get there by working the file, and rating the client properly rather than defaulting to low.
The six matters, same as everyone
For any of these customers you must establish, on reasonable grounds (AUSTRAC, node 1308 (opens in a new tab)):
- the identity of the customer
- the identity of anyone the customer is receiving the service on behalf of
- the identity of anyone acting on behalf of the customer, and their authority to act
- the identity of any beneficial owners
- whether any of those people are a politically exposed person (if they are individuals) or designated for targeted financial sanctions
- the nature and purpose of the business relationship or occasional transaction.
The list is identical to a company's. What changes is where you find each answer.
Who the customer is, when there is no ASIC extract
A company has a name on the companies register. A partnership often has nothing comparable, and AUSTRAC deals with that directly: for a partnership or unincorporated association that does not operate under a business or charity name, the customer's full name is the names of all the partners or members (AUSTRAC, node 1308 (opens in a new tab)). The farming partnership's "name" is the three family members.
The rest of the identity collection follows the company pattern, with substitutions:
- Business names and other names the customer uses, including any registered business name.
- A unique identifier, if one exists. Usually an ABN. AUSTRAC accepts that some customers have none, giving the example of an incorporated association that does not carry on a business, such as some charities or sporting groups.
- Principal place of business or operations, and any separate registered office.
- Evidence the customer exists. For a partnership, AUSTRAC's examples are the partnership agreement (or a foreign certificate of registration). For incorporated or unincorporated associations, the constitution. Register searches such as ABN Lookup and the ASIC business names register also help.
- The powers that bind and govern it. The partnership agreement, or the association's constitution or rules.
- The individuals responsible for governance and executive decisions. For an incorporated association, AUSTRAC's example is the committee.
To verify a partnership's name, AUSTRAC points to the partnership agreement (or a reliable copy or extract) plus the partnership's ABN, if any. For an unincorporated association, the rules or constitution, or other reliable and independent data, plus any ABN (AUSTRAC, node 1308 (opens in a new tab)).
The practical upshot: the partnership agreement is to a partnership what the trust deed is to a trust. It proves existence, sets out the powers and, as the next section shows, tells you who the beneficial owners are. Ask for it at engagement, and ask whether it has been varied. A handshake partnership with no written agreement is not automatically a problem, but it means you will lean harder on other reliable data and you should note why.
Beneficial owners: 25%, or control
A beneficial owner is an individual who directly or indirectly owns 25% or more of the customer, or controls it. For anything that is not a company, control is assessed through two tests: whether a person can control the composition of a governing body (AUSTRAC lists trustees, managers and committee), and practical influence over financial and operational decisions (AUSTRAC, determining ownership and control (opens in a new tab)).
You verify the ownership and control structure against documents such as the constitution or rules, ASIC registers, member statements and partnership agreements (AUSTRAC, node 1308 (opens in a new tab)).
AUSTRAC's own worked example is worth copying into your procedures. A law firm's prospective customer is 123 Limited Partnership. Under the partnership agreement:
- Company Z is the general partner, holds 55% of the capital and all the voting rights, and is not acting as a nominee. Jane Smith is its sole shareholder.
- Tom Davis is a limited partner with 25% of the capital and no voting rights.
- Lily Chen is a limited partner with 20% of the capital and no voting rights.
The answer: Tom is a beneficial owner on his 25% alone. Jane is a beneficial owner through Company Z, which controls the partnership. Lily is not, on those facts: under the threshold and without control (AUSTRAC, node 1343 (opens in a new tab)).
Two lessons travel to ordinary files. First, follow the chain: a company as partner means you identify the individuals behind it, exactly as you would with a company client's beneficial owners. Second, the 25% line is real. Being a partner does not automatically make someone a beneficial owner, and identifying everyone "to be safe" is a choice, not the rule. Equally, someone below 25% who in practice runs the place meets the control test.
For a club or association, ownership percentages rarely mean anything. Control does. Look at who can appoint or remove the committee, and who actually makes the financial decisions.
If you genuinely cannot identify the beneficial owners, AUSTRAC treats the matter as established if you have taken all reasonable steps, recorded the steps and the difficulties, collected the identity of the chief executive officer or equivalent, and verified information as appropriate to the risk (AUSTRAC, node 1308 (opens in a new tab)). That is a documented fallback, not a shortcut: the file note is the thing doing the work.
The treasurer is not the customer
Partnerships and associations almost always deal with you through one person: the managing partner, the club treasurer, the association secretary. AUSTRAC calls this a common requirement for these customer types. You identify the representative who engages with you on the designated service (not every office-holder the customer has) and you establish and verify their authority to act (AUSTRAC, node 1308 (opens in a new tab)).
Authority is the part that is never skipped. Even where the representative's own identity can be taken as established without verification (low added risk, adequate KYC, no grounds for doubt), AUSTRAC says you still need to verify their authority. Its examples of reliable evidence include written confirmation from an employer, or a letter, agency agreement or other authorisation from the customer. For a club, the natural source of that authorisation is the committee. We have covered the representative rules in more depth in the person giving you instructions is not your customer.
Nature and purpose: "a tennis club" is an answer
You must at least collect information about the nature of the customer's business or operations. If it is not commercial, AUSTRAC expects you to collect its purpose, and its own examples are a tennis club and a wildlife rescue association. You also collect why the customer wants your services (AUSTRAC, node 1308 (opens in a new tab)).
You generally do not need to verify this matter unless enhanced CDD applies or you doubt what you were told. If you do need to, AUSTRAC lists sources such as business activity statements, letters from the customer's lawyer or accountant, reliable third-party information, and searches of the ACNC charity register and the ATO's deductible gift recipient register.
Why bother writing "tennis club, selling surplus clubhouse to fund new courts" in the file? Because it is the baseline your ongoing monitoring measures against. A sporting club that suddenly wants to move funds offshore is only unusual if you recorded what usual looked like.
The strata carve-out
One exception deserves more attention than it gets. You are taken to have established the beneficial owners (and their PEP and sanctions status) where the customer is low risk, enhanced CDD does not apply, and you are satisfied on reasonable grounds that the customer is, or is controlled by, a corporation or association of homeowners in a strata title or community title scheme. The same carve-out covers customers overseen by a prudential, insurance or investor protection regulator, and listed companies and government bodies have their own exemption (AUSTRAC, node 1308 (opens in a new tab)).
Read the scope carefully. The carve-out removes the beneficial owner step. It does not remove the rest: you still verify the identity of the customer itself, any representative who deals with you, and anyone the customer is acting for, and you still run PEP and sanctions checks on them. An owners corporation engaging you is a short file, not an empty one.
Low risk files get lighter
Where the customer is low risk, enhanced CDD does not apply, you have collected KYC information appropriate to the risk and you have no reason to doubt it, you are taken to have established the identity of the representative, the person on whose behalf the customer is acting, and the beneficial owners without verifying that information (AUSTRAC, node 1308 (opens in a new tab)). You still collect it. You just do not have to chase verification documents for each person.
For the two-GP practice that has banked with the same institution for twenty-five years and wants help with a property purchase, that is a meaningful saving. It is only available after the risk assessment, though, which is why the rating comes first.
A worked file: the tennis club
Riverbend Tennis Club Inc is selling its old clubhouse, and your firm is acting on the sale. It is an incorporated association with an ABN, a constitution and a five-person committee. The treasurer, Priya, is your contact.
- Customer identity: the association's full name, ABN, principal place of operations, the constitution as evidence of existence and governing powers, and the committee members' names.
- Representative: Priya identified, plus written authority from the committee to instruct you on the sale.
- Beneficial owners: no one owns 25% of a members' club, so the question is control. The constitution says the committee is elected by members and the committee makes the financial decisions. Record that analysis, and identify whoever the control test lands on.
- PEP and sanctions: run across the club, Priya and the beneficial owners you identified. If a screening check returns a match, you resolve it before acting.
- Nature and purpose: amateur sporting club, selling surplus property to fund new courts.
- Risk rating: recorded with reasons.
None of this needs the original documents in a drawer. AUSTRAC notes you are not required to keep the documents themselves and can record their details instead (AUSTRAC, node 1308 (opens in a new tab)). What you must keep is the record of what you collected, the data's type and content, and your risk decisions, for 7 years after the business relationship ends (AUSTRAC, overview of initial CDD (opens in a new tab)). More on that in what to keep and what to destroy.
The short version
- The partnership agreement or the constitution is the core document. Ask for it first.
- No business name means the customer's name is the list of partners or members.
- Beneficial owner is 25% or control. A partner below 25% without control is not one; a committee that runs everything may be.
- Identify the representative, and always verify their authority.
- Strata and community title bodies can skip the beneficial owner step if they are low risk. Nothing else.
If your firm's CDD forms only come in individual, company and trust versions, this is the gap to close before the next partnership walks in. The family trust version of this walkthrough is here.
Not sure where your gaps are? The free compliance check takes two minutes, no signup, and shows you where your current setup stands against the new obligations.
This article is general information, not legal advice. For advice specific to your circumstances, consult a qualified AML/CTF professional.