What onboarding checks are required for a self-managed super fund (SMSF)?

SMSFs are a common client type for accounting firms and financial advisers, and they present specific AML/CTF verification challenges. The combination of a trust structure, multiple trustees, and sometimes complex investment activities means SMSF onboarding requires careful attention to beneficial ownership.

Step 1 — Verify the SMSF as an entity

• Confirm the fund's ABN on the Australian Business Register (ABR) — the ABN search at abr.business.gov.au will confirm the fund name, registration status, and GST status
• Obtain the trust deed — this establishes the fund's legal structure, identifies the trustees and members, and sets out the fund's governing rules
• Note the fund's ATO registration as a regulated superannuation fund — all legitimate SMSFs are registered with the ATO

Step 2 — Identify and verify trustees

An SMSF can have individual trustees or a corporate trustee (a company that acts as the trustee). Your verification obligations differ depending on the structure:

• Individual trustees: Identify and verify each trustee (typically 1–4 individuals) using standard CDD — government-issued photo ID, confirmed against DVS where possible
• Corporate trustee: Identify the company (ACN, registered name), verify the company exists via ASIC, and then identify and verify each director of the corporate trustee as individual persons

Step 3 — Identify beneficial owners (members)

In an SMSF, the members are both the trustees and the beneficiaries. Each member has an equitable interest in the fund's assets. You must identify all members — typically the same individuals as the individual trustees — and understand what percentage of the fund's assets each member is entitled to.

Step 4 — Screen all trustees and members

Screen every individual trustee, every director of a corporate trustee, and every member against PEP and sanctions lists. Record the screening date, list version, and result for each person. Remember to set up ongoing screening — SMSF trustees and members should be re-screened at regular intervals.

Why SMSFs can present elevated risk

SMSFs can hold significant assets — property, shares, gold, and other investments — and may receive large contributions. Complex or unexplained transactions, or an SMSF with limited contributions history suddenly receiving large transfers, can be red flags warranting enhanced scrutiny.