A register hit is only the beginning of a cross-border counterparty check. Before signing or paying, the decision-maker needs to know which legal person is involved, what the official records actually establish, where ownership or authority remains uncertain, and whether the proposed payment destination has been independently verified. The steps below are a reusable decision record for an Australian organisation dealing overseas. They are proportionate to the value and risk of the transaction, and do not replace legal, sanctions, tax or regulated anti-money-laundering advice.
1. Freeze the identity supplied in the proposal
Obtain the proposed contract, invoice and onboarding details before searching. Record the exact legal name in its original script, registration number, jurisdiction, registered address, trading names, signing person and stated role. Separately record the invoice issuer and account beneficiary. Ask which entity will deliver the goods or services and which entity will receive money. A brand, website, group name or local branch may not be the contracting legal person. Search by the identifier and name, including former names and transliterations where relevant. Save the result date and the official record URL or extract. ASIC says its registers can be searched by name or unique number and that a registered company is not necessarily safe to deal with. ASIC company and organisation registers; ASIC: dealing with businesses and companies.
2. Use the register for the right jurisdiction and note its coverage
For an Australian company, check ASIC’s company register; use the Australian Business Register’s ABN Lookup for an ABN and its public details. For a New Zealand company, use the Companies Office search. For a UK company, start with Companies House. For another jurisdiction, locate its government or statutory corporate register rather than assuming a commercial aggregator is official. Record the register’s update date, whether it provides current and historical filings, what costs or permissions limit access, and which fields are self-reported. The New Zealand Companies Office, for example, explains that only the ten largest share parcels are shown for listed companies or those with extensive shareholdings. NZ Companies Office search guidance.
Compare the result with the contract and invoice. Resolve changed names, inactive status, a similarly named company, or a mismatch between the registered entity and the signatory before committing. A clean registration entry confirms specific recorded facts; it does not prove trading performance, authority of a particular person, absence of litigation, or honesty.
3. Map ownership and control without pretending the public record is complete
List the immediate shareholders or members available from official filings, then follow corporate shareholders through their own jurisdictions where justified. Distinguish legal shareholding, beneficial ownership and practical control. Ask the counterparty for an ownership chart and supporting documents when a material link cannot be established publicly. Check dates: a filing may lag a transfer. Treat nominees, trusts, private companies and multi-layer structures as gaps to explain, not proof of misconduct. FATF’s guidance calls for adequate, accurate and current beneficial-ownership information, but the access mechanisms and visibility differ by country; a public search alone may not reveal the natural person who ultimately controls an entity. FATF beneficial-ownership guidance.
4. Verify the payment recipient through an independent channel
Compare the beneficiary name and bank details on the invoice with the contracting entity and the approved supplier record. A different beneficiary may have a legitimate explanation, but require documentary authority and approval before payment. For a new account or changed instruction, call a verified contact using a number already held or independently obtained from a trusted source; do not rely on the phone number in the change email. Record who answered, when, what details were confirmed and who approved the exception. The ACCC advises independent verification of changed payment details in response to business-email-compromise and payment-redirection scams. Scamwatch: business email compromise.
If your Australian bank provides Confirmation of Payee, use its displayed match result as one signal, not as proof that the supplier authorised the payment. The service compares entered name, BSB and account number with receiving-bank details for supported domestic payments; it does not replace a trusted callback and may not cover an overseas transfer. Australian Payments Plus: Confirmation of Payee.
5. Screen sanctions and resolve possible name matches
Search the legal entity, known aliases, relevant owners/controllers and payment beneficiary against DFAT’s Australian Consolidated List close to the decision and again if material parties change. Record list version or access date, search terms and result. DFAT says its list covers Australian sanctions, including relevant UN listings, but not every other country’s laws. Where another jurisdiction’s sanctions could apply, obtain advice and consult that jurisdiction’s official source (for example, US OFAC or the UK Sanctions List). DFAT list and scope.
A matching name is a lead, not a confirmed identity. Compare the list’s aliases, date of birth, location, registration number and other identifiers with lawfully held counterparty information. Record contradictory identifiers as carefully as supporting ones. Do not clear a close match solely because one field is blank. DFAT’s guide explains the information fields and alias types. If a possible match remains, pause the dealing and obtain sanctions advice; DFAT expressly recommends legal advice for a match. DFAT list guide; DFAT match guidance.
6. Evaluate adverse information by source and outcome
Write the specific allegation or risk question before searching. Prefer official judgments, regulator notices and primary corporate filings over an unattributed search result. Capture publication date, jurisdiction, case or notice number, party identifiers and current procedural status. Separate an allegation, charge, finding, appeal and later correction. Multiple sites repeating one story are one source chain, not independent corroboration. Give the counterparty a fair opportunity to explain a material discrepancy where appropriate and safe. Public records can be incomplete, delayed or unavailable; an absence of adverse results is not evidence of an absence of risk.
Reusable counterparty checking worksheet
Copy the following fields into a transaction file. Write “not established” instead of leaving a material field blank.
- Decision: proposed transaction, value/risk, decision owner, deadline and jurisdictions touched.
- Entity: exact registered name, original script, number, register URL/extract and search date; trading names and former names.
- People and authority: signatory, stated role, source of authority, identifiers checked and unresolved name matches.
- Ownership: immediate holders, source and date; claimed ultimate controllers; unavailable layers and documents requested.
- Payment: invoice issuer, beneficiary name, account/country, first or changed instruction, independent callback details, bank match signal and approver.
- Sanctions: applicable regimes considered, official lists checked, names/aliases searched, date, match resolution and adviser referral.
- Adverse information: claim, primary source, date, current status, identity basis, response and contrary evidence.
- Decision record: established facts, gaps, escalation owner, condition before signing/payment, next review date and final authorisation.
Worked decision — mismatched payment details
Hypothetical example. “Harbour Components Ltd” offers parts through a sales agent, while the invoice names “Harbour Components Trading Pte Ltd” and directs payment to an account in a third country. The Australian buyer finds a live company registration for the first name, but no official record yet connecting it to the invoice issuer. The agent’s email says the account changed yesterday. The correct interim conclusion is identity and payment authority not established, not “fraud”. The buyer pauses payment, obtains both legal entity numbers and an ownership/agency explanation, verifies each against its home register, calls a previously verified supplier contact, checks relevant sanctions names and records approval of any third-party payment arrangement. If the supplier cannot substantiate the relationship or the payment instruction, escalate to legal and finance leadership; a larger or regulated transaction may require specialist due diligence.
Public records cannot by themselves establish the ultimate beneficial owner in every jurisdiction, the legitimacy of a changed bank account, the absence of undisclosed misconduct or whether a particular transaction complies with every applicable sanctions regime. A useful due-diligence note ends with the decision that can be made now, the conditions for proceeding and the questions that remain open.