Aspire Australia currently supports the following Australian entity types:
Domestic Proprietary Company (Pty Ltd)
Discretionary Trust (sometimes also known as a Family Trust)
Sole Trader
Partnership (general partnerships consisting only of individual partners)
The documents required to open an Aspire account depend on your business type and complexity. This page summarises the documents we collect for each entity type to comply with Australia's Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) Rules administered by AUSTRAC.
Domestic Proprietary Company (Pty Ltd)
For a domestic proprietary company, the key information we collect and verify includes:
Company name (as registered with ASIC)
Australian Company Number (ACN) and/or Australian Business Number (ABN). Where both are available, we prefer the ABN as it includes the ACN.
Evidence of existence
Registered address
Principal place of business
Trading name(s) / business name(s), if any
Names of all directors
Nature and purpose of the business relationship
Ultimate Beneficial Owner (UBO) / Controller details
Discretionary Trust
Discretionary trusts (often called family trusts) are unregulated by ASIC, so the Trust Deed is the primary verification document. For a discretionary trust, the key information we collect and verify includes:
Full name of the trust - verified via Trust Deed
Trading name(s) / business name(s), if any
ABN, where available
Type of trust
Country of establishment
Full name of all trustees
Evidence of existence
Settlor details - required only where the material asset contribution at the trust's establishment exceeded $10,000 (subject to certain exemptions)
Beneficiary class details
Principal place of business
Ultimate Beneficial Owner (UBO) / Controller details
If a trustee is a domestic proprietary company, we will also collect and verify the information about that trustee as set out in the domestic proprietary company section. If a trustee is an individual, we will also collect and verify the information set out in the UBO/Controller section.
Sole Trader
As a sole trader, the individual and the business are legally the same entity. Identity verification of the individual also serves as business verification. For a sole trader, the key information we collect and verify includes:
Full name (including any aliases)
Date of birth
Residential address
Trading name(s) / business name(s), if any
ABN, where available
Principal place of business (your residential address may be used as a fallback)
Partnership
In Australia, partnerships are not separately incorporated. Verification of a partnership mainly comes from the Partnership Agreement (or a certified copy/extract). For a partnership, the key information we collect and verify includes:
Full name of the partnership
Trading name(s) / business name(s), if any
ABN, where available
Full name of each partner
Residential address of each partner
Country of establishment
Partner with most ownership
Ultimate Beneficial Owner (UBO) / Controller details
Identity verification documents
For each individual who we need to identify (such as admin users, directors, UBOs, Controllers, sole traders, partners, and individual trustees), the key information we collect and verify includes their: full name, date of birth, residential address, ID number, ID expiration date, nationality, ownership/control percentage, and proof of address (where the individual’s nationality is a prohibited country).
For Australian individuals, we accept the following ID documents:
Australian Passport
Australian Driver's Licence
Foreign Passports are also accepted for non-Australian individuals (e.g. directors or UBOs based overseas). All ID documents must be valid and not expired.
Identity verification is performed electronically via our trusted service providers such as Onfido, which includes using Australia's Document Verification Service (DVS) and other identity verification data sources.
Ultimate Beneficial Owners (UBOs) and Controllers
A UBO is any individual who directly or indirectly holds 25% or more of ownership or control of the entity. If no individual qualifies as a UBO based on ownership, we identify the Controller - the individual who exercises control through a board, committee, appointor, or by position rather than by shareholding.
How UBOs and Controllers are identified depends on entity type:
Domestic Proprietary Company - shareholders holding 25% or more. Where a corporate shareholder holds 25% or more, we look through to the ultimate individual(s) at the top of the chain.
Discretionary Trust - the appointor as Controller.
Partnership - partners with controlling interest, plus a Controller where no partner meets the ownership threshold.
Sole Trader - not applicable; the individual is the UBO.
Letter of Authorisation (Non-Director)
A Letter of Authorisation (LOA) is required where the user opening the account is doing so on behalf of a company, but is not a director of that company. The LOA is a signed document authorising that user to open and operate the Aspire account on behalf of the company. Signing requirements:
Companies with multiple directors: signed by two directors
Companies with one director: signed by the sole director
Partnerships: signed by a partner
A new LOA is required whenever a new non-director admin is added or a control person changes.
Information for all directors
For all entity types that are companies, we collect the following information for every registered director: full name, date of birth, nationality, country of residence, and ID number. Valid ID and a liveness check are required for at least one director.
ABN or ACN - which one does Aspire need?
Where your company has both an Australian Business Number (ABN) and Australian Company Number (ACN), we prefer to collect the ABN. If your company does not have an ABN, the ACN alone is sufficient. If your business does not have an ABN, we may ask you to explain why you are operating a business without an ABN.
Do I need to provide details of every shareholder of my company?
No, not necessarily, as we will collect the initial information we need about the shareholders of your company from ASIC. We might need to ask for more information about any shareholder who is a UBO.
For example: where a corporate shareholder holds 25% or more, we look through to the ultimate individual(s) at the top of the chain. Where a trust holds 25% or more, we additionally apply our Trust due diligence to that trust and request the Trust Deed to identify the UBO.
What if no individual qualifies as a UBO of my company?
If no individual holds 25% or more of your business, we identify a Controller, the individual who exercises ultimate control by other means, such as through a board, committee, appointor, or by position. For a domestic proprietary company, this is typically evidenced via a Disclosure Certificate (Company Declaration) and/or a Company Org Chart. The Controller is verified to the same standard as a UBO.
Why do I need to confirm details of all directors, even if Aspire only verifies one ID?
For all entity types that are companies, director information must be collected for the customer entity. We record the full name, date of birth, nationality, country of residence, and ID number of every director. For verification purposes, a valid ID for at least one director must be on file, and a liveness check via Onfido is required. (Note: this applies to directors of the customer entity itself, not to directors of corporate shareholders, who are addressed through our look-through process for UBOs.)
Do trusts need to provide details of every beneficiary?
For discretionary trusts, non-discretionary trusts typically only specify classes of beneficiaries rather than a defined list of named individuals. Because there is no individual who 'owns' 25% or more of the trust assets, we instead identify the appointor of the trust as the Controller, and verify their identity.
The appointor is a person who has the power to appoint the trustees to the trust. The name of the appointor is usually found in the trust deed. The trust deed might describe the “appointor” as something else such as a “guardian”, “controller”, “nominator”, “protector” or “principal”.
When does Aspire need to verify the identity of a settlor of a trust?
Settlor identity verification is generally required only where the material asset contribution at the time the trust was established exceeded $10,000. This is rarely the case, so we often do not have to verify the identity of the settlor.
My partnership doesn't have a written Partnership Agreement - what do I do?
The Partnership Agreement (or a certified copy/extract) is the primary verification document for partnerships. Where a formal Partnership Agreement is unavailable, a Disclosure Certificate (Entity Declaration) can support verification. We may also rely on reliable independent electronic data sources.
