Bank entitled to seek information about body corporate before opening accounts

Categories:

Bank accounts, Bank decisions,

Summary:

In February 2026, Gordon applied to open bank accounts for two bodies corporate. The bank asked for information as part of its obligations under the Anti-Money Laundering and Countering Financing of Terrorism Act 2009. Gordon supplied only some of the information, saying the Anti-Money Laundering and Countering Financing of Terrorism (Class Exemptions) Notice 2018 exempted body corporate managers from supplying information to meet banks’ customer due diligence obligations. The bank disagreed and did not open the accounts.

Published:

August 2026

Our investigation

Gordon’s argument is that body corporate managers are exempt. The bank’s argument was that it did not require identification and verification of every unit owner in every case. Rather, its due diligence was directed at the body corporate, people acting on its behalf, and any individuals who were beneficial owners through ownership or effective control.

We found the bank was required to carry out customer due diligence before opening accounts for a body corporate. This included identifying and verifying relevant beneficial owners.

We also found the exemption Gordon relied on did not remove the bank’s obligation to carry out customer due diligence when opening an account for a body corporate, and that the bank was entitled to request customer due diligence information before opening the accounts.