Case study
AUSTRAC · APP 3

Why does the bank want everyone’s licence?

Short version: no. The bank must identify the owners corporation and verify the people who actually deal with it — the account signatories and anyone giving it instructions. It does not have to verify every committee member, and for a strata scheme AUSTRAC expressly lets it skip the beneficial-owner step that would otherwise pull in everyone with control. Names of the office-bearers and the minutes appointing them are a normal request; licences and dates of birth for committee members who will never touch the account are not. Owners who are not on the committee are not part of it at all.

WhoWhat the bank can reasonably ask for
The owners corporationFull identification — name, strata plan number, address, and usually a copy of the registered plan and recent AGM minutes.
Account signatories and anyone instructing the bankFull identity verification, politically-exposed-person and sanctions checks, and proof of their authority to act — typically the minutes or resolution appointing them.
Chairperson, secretary and treasurerNames, and possibly more under a bank’s older procedures — see below. A reasonable request either way.
Other committee membersNothing, as a legal requirement. If they do not operate the account or instruct the bank, the anti-money-laundering rules do not reach them.
Owners who are not on the committeeNothing. The bank’s customer is the owners corporation, not each owner, and paying levies into the account does not make you its customer. An owner who holds no office and does not operate the account is outside these checks entirely.

It is the role that counts, not being an owner. In a small scheme the roles overlap — the treasurer is often also a signatory, and in a two- or three-lot scheme every owner may sit on the committee — so find your own row by what you actually do, and where you hold more than one role, the most demanding row applies.

Where the customer is low risk and is “a corporation or association of homeowners in a strata title or community title scheme”, the bank is taken to have established the identity of its beneficial owners. It must still verify, and run politically-exposed-person and sanctions checks on, the owners corporation and any representative that engages with it. In AUSTRAC’s words: “You don’t need to verify every representative that the customer has.”

What you need in front of you

  • The bank’s written request. Exactly who it wants identified and what it wants from each. Requests made over the phone tend to grow in the retelling.
  • The minutes appointing your office-bearers. Most recent AGM or committee minutes showing who holds each office.
  • A resolution naming the signatories. The committee or general-meeting resolution authorising who may operate the account. This is what proves their authority.
  • The strata plan number and registered address. To identify the owners corporation itself.

If the bank asks for everyone: step by step

  1. Ask which obligation it is relying on. A polite written question — which rule requires identity documents from committee members who will not operate the account? AUSTRAC’s own guidance points the other way, and asking often resolves it at the first conversation.
  2. Offer the standard package. Names of the office-bearers, the minutes appointing them, the resolution authorising the signatories, and full identification from the signatories only. That is what a bank’s published strata checklist typically asks for.
  3. Let each person give their own documents. The committee should not collect members’ licences and forward them. Each signatory provides their own identification to the bank directly.
  4. Accept the three office-bearers if the bank insists. Some banks are still on their pre-reform procedures, which is allowed until 31 March 2029, and the older fallback reached the presiding officer, secretary and treasurer. Holding out on those three is rarely worth losing the account over.
  5. Complain if it will not budge beyond that. Use the bank’s internal complaints process first, then the Australian Financial Complaints Authority. If the objection is specifically over-collection of personal information, the OAIC takes privacy complaints.
Practice note
Remember the bank is allowed to refuse service. The rules set a minimum, not a maximum, and a bank can collect extra information where it judges the risk calls for it. The argument that works is not “you can’t ask” but “this is more than the rules or your own checklist require — why?”

The long version — why the rules stop where they do

Under the anti-money-laundering reforms that began on 31 March 2026, a bank opening an account for a body corporate or association must establish the customer’s identity, the identity and authority of anyone acting on its behalf, and its beneficial owners, and screen them for political exposure and sanctions. For most organisations the beneficial-owner step is what reaches widest — it covers anyone who owns or controls the entity.

Strata is carved out of that step. AUSTRAC’s guidance names a corporation or association of homeowners in a strata title or community title scheme as a low-risk customer for which beneficial ownership is taken to be established. What remains is the owners corporation itself and the representatives who engage with the bank — and AUSTRAC adds that the bank only needs to identify representatives who deal with it, not every representative the customer has.

The office-bearer question comes from the older rules. AUSTRAC’s earlier strata guidance, applying the pre-reform framework, said that where beneficial owners could not be worked out a bank could verify the senior managing officials, which it said were likely to include the presiding officer, secretary or treasurer. The transitional rules let banks keep their existing identification procedures until 31 March 2029, so you will still meet that request — and it is defensible for those three. It does not extend to the rest of the committee.

The ceiling comes from privacy law. A bank may collect only what is reasonably necessary for its functions, an objective test the OAIC applies to AML collection as well: identity data the rules prescribe will generally pass, but the OAIC’s guidance to reporting entities stresses data minimisation — information that is relevant, minimal and not excessive. Identity documents for people the rules do not reach are hard to fit inside that.

The official sources

Current as at 27 September 2026. Strata surfaces statutory rules as guidance, but it is record-keeping software, not legal advice, and no page here accounts for the particulars of your scheme. Check the Act, your registered strata plan and your by-laws, and get advice before acting on anything with money or a dispute attached.