Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF)

At BCI Business Brokers, we are committed to maintaining the highest standards of integrity, transparency, and compliance in all business transactions we facilitate.

As part of our obligations under Australian Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) requirements, we may need to collect and verify certain information from clients and parties involved in a transaction. These requirements help ensure that businesses operate in a secure and trusted environment while reducing the risks associated with financial crime.

We understand that providing personal information may raise questions or concerns. These requirements are in place to help protect businesses, clients, and the wider community from financial crime. The information collected is handled securely and used only for the purposes required under applicable AML/CTF regulations.

For more information about why identity verification and customer due diligence requirements exist, you can visit the official guidance provided by Australian Transaction Reports and Analysis Centre (AUSTRAC).
Website Link: https://www.austrac.gov.au/general-public

Purpose

This Anti-Money Laundering (AML) Policy establishes the procedures and controls designed to reduce the risk that BCI’s services may be misused for money laundering, terrorism financing, fraud, or other unlawful activities.

This policy provides guidance for identifying clients, assessing risks, conducting verification checks, maintaining records, and escalating concerns.

Scope

This policy applies to:

• Directors and employees of BCI Business Brokers
• Contractors and consultants involved in client onboarding
• Vendors selling businesses through BCI
• Buyers seeking to acquire businesses through BCI
• Any third parties involved in business transactions facilitated by BCI

BCI Business Brokers Pty Ltd (BCI) is committed to maintaining high standards of integrity, transparency, and ethical business practices.

This Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) Policy establishes the procedures and controls designed to reduce the risk that BCI’s services may be misused for money laundering, terrorism financing, fraud, or other unlawful activities.

This policy provides guidance for identifying clients, assessing risks, conducting verification checks, maintaining records, and escalating concerns.

Commitment to AML/CTF Compliance

BCI recognises the importance of preventing financial crime and is committed to:

• Conducting appropriate due diligence on clients
• Understanding who we are dealing with
• Identifying beneficial owners and controlling parties
• Maintaining accurate client records
• Identifying and managing potential risks
• Escalating suspicious activity appropriately

BCI will not knowingly provide services to individuals or organisations involved in illegal activities.

As part of our Anti-Money Laundering (AML) compliance process, we use the Didit platform to assist with identity verification.

Didit applies industry-standard security measures and compliance practices to protect personal information collected during the verification process. For more information about how Didit handles data, privacy, and security compliance, please refer to their official security and compliance information:

Didit Security & Compliance

Customer Identification Program (KYC)

Before establishing a business relationship, BCI will collect and verify appropriate information about clients.

Individual Clients

For individual buyers and vendors, BCI may collect:

• Full legal name
• Date of birth
• Residential address
• Contact details
• Government-issued identification documents

Accepted identification documents may include:

• Australian passport
• Foreign passport
• Australian driver licence
• Other approved identity documents

Company Clients

Where a buyer or vendor is a company, BCI will collect:

• Company name
• Australian Business Number (ABN)
• Australian Company Number (ACN)
• Registered address
• Directors’ details
• Shareholders’ details
• Ownership structure information

BCI may request:

• ASIC company extract
• Trust documentation
• Ownership structure charts
• Other supporting documents

AML Compliance Officer

BCI will appoint an AML Compliance Officer responsible for overseeing AML/CTF processes.

The AML Compliance Officer’s responsibilities include:

• Maintaining AML policies and procedures
• Ensuring client identification processes are followed
• Reviewing higher-risk clients
• Managing AML records
• Coordinating staff training
• Reviewing compliance effectiveness

Beneficial Ownership Identification

BCI will identify individuals who ultimately own or control a company, trust, or other legal structure.

Where ownership is complex, BCI may request additional information to understand:

• Ownership percentages
• Controlling parties
• Directors and decision-makers
• Source of authority to act on behalf of the entity

Identity Verification

BCI may use electronic identity verification services to confirm client identity.

Verification checks may include:

• Document authenticity checks
• Identity matching
• Facial verification
• Liveness detection
• Sanctions screening
• Politically Exposed Person (PEP) screening

Verification results will be recorded within BCI’s client management system.

Enhanced Due Diligence

Additional checks may be required for higher-risk clients.

Enhanced due diligence may include:

• Additional identity documents
• Verification of ownership structures
• Confirmation of source of funds
• Senior management approval
• Additional monitoring

Politically Exposed Persons (PEP) 

BCI will identify clients who may be classified as Politically Exposed Persons.

Where a PEP is identified:

• Additional checks may be performed
• The relationship may require management approval
• Additional monitoring may be applied

Sanctions Screening

BCI may conduct sanctions screening to identify whether clients appear on relevant sanctions lists.

If a potential match is identified:

• The matter must be escalated immediately
• No further action should be taken until reviewed
• Approval from the AML Compliance Officer is required

Suspicious Activity Identification 

Employees should be alert to unusual activities, including:

• Client refusing to provide identification
• False or inconsistent information
• Unclear ownership structures
• Requests to bypass normal procedures
• Unusual urgency around transactions
• Third-party involvement without a clear reason
• Information that does not align with the proposed transaction

Any concerns must be reported internally to the AML Compliance Officer.

Client Approval Process

Before providing confidential business information, including Information Memoranda or detailed financial information, BCI may require:

• Completion of client registration
• Identity verification
• AML risk assessment
• Approval of buyer/vendor status

Record Keeping

BCI will maintain records relating to:

• Client identification
• Verification results
• Risk assessments
• Communications
• Approvals
• Supporting documents

Records will be stored securely and retained for the required period under applicable legislation and business requirements.

Data Security and Privacy

BCI recognises that identity documents and client information are sensitive.

BCI will:

• Store information securely
• Restrict access to authorised personnel
• Protect confidential client information

Client information will be handled in accordance with BCI’s Privacy Policy.