How AMLHive routes entity KYB to the right CDD tier — automatically

The entity-type routing table

Every KYB verification in AMLHive is assigned one of three CDD tiers: Simplified, Standard, or Enhanced. The tier is determined automatically based on the entity type you select and what the free government data feeds return. The table below shows how each entity type routes.

Simplified CDD — what it is and who qualifies

Under AUSTRAC's Simplified CDD guidance (AML/CTF Act 2006, Part 2, Division 6, ss. 32–40), a reporting entity may apply a lighter verification standard when the customer belongs to a category that presents a low inherent ML/TF risk. The rationale is that these entities are already subject to a comparable regulatory regime or public disclosure obligation that makes beneficial-owner concealment structurally difficult.

AMLHive automatically grants Simplified CDD to five entity types — and only when the specific statutory condition is met:

• ASX or ASX Debt-listed public companies — listed companies must file continuous disclosure, shareholder registers are public, and ASIC maintains live entity status. Simplified CDD applies only when the exchange is confirmed as ASX or ASX_DEBT and the ASIC record is ACTIVE. A company that is listed but administratively inactive does not qualify.
• APRA-regulated subsidiaries— subsidiaries of ADIs, insurers, and superannuation trustees regulated by APRA are deemed low-risk by virtue of the parent's prudential obligations. Simplified CDD applies when the parent ACN is confirmed against AMLHive's curated APRA allowlist.
• Government bodies — all government entities (Commonwealth, state, territory, or local) qualify automatically. AMLHive verifies the ABN against the ABR and confirms the entity type is government.
• ACNC-registered charitable trusts— charities on the Australian Charities and Not-for-profits Commission (ACNC) register with status "Registered" qualify. AMLHive cross-references the supplied ABN against the live ACNC register. A charity that has been deregistered does not qualify and is routed to Standard CDD.
• Registered managed investment schemes— schemes with an ARSN are regulated by ASIC and the responsible entity must hold an Australian Financial Services Licence. AMLHive verifies the responsible entity's ACN directly in the ASIC dataset.

For all other listed companies (NYSE, LSE, etc.) that are not registered on ASX or ASX Debt, the system routes to Standard CDD. AMLHive still identifies directors from the ASIC officeholder record but does not require individual director KYC — because even under Standard CDD, directors as officeholders are not the same as beneficial owners. Director KYC is only required if a director also holds ≥25% beneficial ownership as a shareholder.

The director exemption rule — what requires_individual_kyc means

Every director AMLHive records from the ASIC officeholder dataset is stored as a UBO record with two fields that tell you what action is needed:

• requires_individual_kyc — whether this person must complete a full individual KYC check (biometric Veriff flow). For directors captured purely as officeholders, this is always false. The field becomes trueonly when an individual also holds ≥25% beneficial ownership through the shareholder structure.
• kyc_status — NOT_REQUIRED when requires_individual_kyc is false; PENDING when KYC is required and has not yet been completed. For Simplified CDD entities, no director records are created at all — the audit trail records the Simplified CDD determination instead.

This distinction matters for AUSTRAC audits. If an inspector asks why a director of an ASX-listed company did not undergo biometric verification, the answer is grounded in the Act: the entity qualifies for Simplified CDD under s.32, and individual director screening is not a Simplified CDD obligation. The audit trail entry LISTED_COMPANY_SIMPLIFIED_APPLIED records that determination at the time of verification.

For government bodies and registered charities, the system goes further: no director records are created at all, because the entity itself is the regulated subject and its officeholders are not relevant to the CDD assessment.

Standard CDD — private and public companies

Private companies (Pty Ltd), non-listed public companies (Ltd), and foreign companies registered with ASIC (ARBN) all receive Standard CDD. AMLHive:

1. Verifies entity existence and status via the ASIC bulk dataset.
2. Extracts directors from the officeholder register and stores them as UBO records with kyc_status=NOT_REQUIRED — they are identified but not individually screened.
3. Cross-references the ABN with the ABR to confirm entity name and active status.
4. Awaits the ownership document (trust deed, share register) to identify shareholders. Any shareholder at ≥25% beneficial ownership triggers requires_individual_kyc=true and a KYC Pending status.

Foreign companies with an ARBN additionally receive a COMPLEX_OWNERSHIP_STRUCTURE risk flag, which appears on the CDD checklist and may prompt the principal to apply Enhanced CDD criteria.

Enhanced CDD — unregistered foreign companies and foreign trusts

Two entity types automatically attract Enhanced CDD:

• Foreign companies with no ARBN — entities incorporated overseas with no Australian registration. No ASIC or ABR lookup is possible. The system records the country of incorporation and foreign registration number, raises COMPLEX_OWNERSHIP_STRUCTURE, and sets cdd_type=ENHANCED. An Enhanced CDD checklist is opened.
• Foreign trusts — offshore trust structures are inherently higher-risk because beneficiary classes and trustee chains are opaque to Australian regulators. Both FOREIGN_TRUST_STRUCTURE and COMPLEX_OWNERSHIP_STRUCTURE flags are raised.

For Enhanced CDD entities, your agency must complete the ECDD checklist and a principal-level review is recommended before the matter proceeds. AMLHive will not auto-complete the CDD record for these entity types.

Regulatory basis

• AUSTRAC — Simplified customer due diligence guidance
• AML/CTF Act 2006, Part 2, Division 6 — Simplified CDD (ss. 32–40)
• AML/CTF Act 2006, Part 2, Division 5 — Standard customer identification procedures (ss. 28–31)
• AML/CTF Act 2006, s. 37 — designated bodies (listed companies, government entities, regulated financial institutions)
• Australian Charities and Not-for-profits Commission Act 2012 — ACNC registration as the basis for charitable trust Simplified CDD
• Corporations Act 2001, s. 601ED — registration of managed investment schemes

Content reflects AUSTRAC guidance current as of June 2026. Legislative references are to the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) as amended. This article is an informational summary; it is not legal advice.