Network Analysis: The Check That Looks Beyond the Supplier to Who's Behind It

A supplier passes every standard check. Active ABN, registered company, no insolvency entries, no adverse records. The entity looks clean. Then you run network analysis and find it shares a registered office and a website server with a company that was cancelled eight months ago after leaving creditors unpaid — and that one of the associated names on file appears on the ASIC banned persons register under a previous name.

Network analysis does not check the company. It checks the people behind it.

What Network Analysis Checks

The check runs every entity in the analysis set through several independent cross-reference passes:

Person resolution. Live director lookups direct from ASIC's own company register are currently unavailable — ASIC Connect's search now sits behind an invisible CAPTCHA that blocks automated lookups entirely, a restriction ASIC applies platform-wide, not something specific to Gumshoe. To gap-fill this, Gumshoe cross-references entities against four other public registers that do carry named individuals: the ACNC charity register (responsible persons), the ASIC financial adviser register, state trade licence registers, and the Tax Practitioners Board register. Where the same person shows up against two or more entities in the analysis set, that connection is surfaced. ACNC identity matches use a stable ID and are high-confidence; matches from the other registers are name-based and only asserted once the name is confirmed rare enough (appearing on 3 or fewer register records) to rule out a common-name coincidence.

Important distinction: this associate data reflects a role on a different public register — a charity board seat, an adviser licence, a trade licence — not an ASIC company directorship. It is a genuine and often-overlooked signal of shared control, but it should be verified independently rather than treated as equivalent to a confirmed director record.

Risk flag matching. Every resolved name — from the associate cross-reference above — is checked against the ASIC banned and disqualified persons register. Entity names themselves are also matched against the banned register directly, in case a banned individual is trading through an entity bearing their own name.

Beyond people: the check also fingerprints each entity's own infrastructure and history — shared web hosting IP, shared domain, shared registrar, shared trading names, and whether a cancelled entity with a similar name and location appears shortly before this one was registered (a classic phoenix pattern). Clusters of newly-registered or shell-like entities within the set are flagged as well. These signals don't depend on director data at all, so they still fire even where no person-level connection is found.

Why Company-Level Checks Miss This

Company-level checks — ABN status, company registration, insolvency entries — are entity-specific. They tell you what has happened to this company. They do not tell you what the people behind this company have done before.

Phoenix fraud — where a failed business re-registers under a new entity to escape debts — is almost invisible at the company level. The new company is recently registered, has an active ABN, no adverse records, and no insolvency history. All standard checks pass.

At the director level, the picture changes. The same individuals who controlled the failed entity now appear as directors of the new one. Their previous entity entered external administration. Their previous creditors are still owed money. That history is in ASIC's data — but only if you look at who the directors are, not just what company they are currently running.

Shared People Within an Analysis Run

Network analysis compares every entity you include in a single run against each other. Add two or more suppliers to the same analysis and the check surfaces any resolved person — via the associate cross-reference above — who connects to more than one of them, along with shared infrastructure, trading names, and registration timing across the same set.

This pattern appears in bid-rigging arrangements, where nominally independent suppliers coordinating on tenders are actually connected through shared control. It appears in related-party fraud, where a decision-maker at the buyer organisation has a connection — through a relative, a former colleague, or a nominee — to one or more preferred suppliers. Neither pattern is visible without looking at who controls the entities, not just what the entities are.

When to Use It

Network analysis is a paid add-on at A$9.90 per verification run. It is not necessary for every supplier — for low-value, well-established suppliers with a long payment history and multiple reference points, the standard checks are sufficient.

The cases where network analysis earns its cost quickly:

• New suppliers above a spend threshold. For any supplier where the first invoice will exceed A$5,000, the A$9.90 cost for a network analysis run is not a meaningful consideration.
• Suppliers in industries with known phoenix activity. Construction, labour hire, cleaning, and transport all have above-average phoenix fraud rates. New suppliers in these industries warrant a network analysis run as standard, since the cancelled-predecessor check is specifically tuned to this pattern.
• Suppliers introduced through a personal referral rather than a formal tender or procurement process. Referral-based supplier relationships are the most common vector for related-party fraud.
• Re-verification after a significant gap. Changes to the entity's associates, registered infrastructure, or trading names during an existing relationship can signal material changes in who controls it.

The network analysis check is available on any Gumshoe verification. Add it to the run, and the results appear alongside the standard checks in the same report — one document, all findings, timestamped.

Uncommon Insights

Network analysis can uncover a supplier's phoenix activity, which may not be apparent through standard company-level checks. Under section 596A of the Corporations Act 2001, ASIC has the power to wind up a company that has been involved in phoenix activity, but this requires a court order. By analysing cancelled predecessor entities, shared infrastructure, and associate connections, network analysis can help identify potential phoenix activity before it becomes a problem, reducing the risk of financial instability and hidden liabilities.

The ASIC banned and disqualified persons register is a critical component of network analysis, as it provides a comprehensive list of individuals prohibited from managing companies or providing financial services. However, it's essential to note that this register is not foolproof, and individuals may use previous names or aliases to avoid detection. Network analysis helps identify these individuals by cross-referencing every resolved name — entity names and associates alike — against the register, reducing the risk of reputational damage and regulatory fines.

Shared infrastructure is an underused signal in supplier due diligence. Two entities running on the same server, sharing a domain, or registered through the same agent in a short window are not proof of anything on their own — but stacked together with a cancelled predecessor or a shared associate, the pattern becomes hard to explain as coincidence.

While the ATO's ABN register provides a wealth of information on a supplier's tax status and compliance history, it does not provide any information on the individuals behind the company. Network analysis fills part of that gap by cross-referencing associates across the ACNC, ASIC adviser, licensing, and TPB registers, providing a more comprehensive picture of a supplier's risk profile. This can help CFOs and accountants make more informed decisions about who they do business with, reducing the risk of financial loss and reputational damage.