Director & Board Checks: How Gumshoe Cross-References Company Leadership

Many supplier fraud cases involve directors who have a history of running companies into the ground, or individuals who have been formally banned by ASIC from managing corporations. The Phoenix Shield check in Gumshoe is designed to surface these patterns automatically.

What the Phoenix Shield checks

ASIC Connect's live company-officer lookup — the search you'd use to pull a director list by hand — now sits behind an invisible reCAPTCHA that blocks automated requests entirely. This is an ASIC-wide restriction, not something specific to Gumshoe, and it means no automated tool can pull a live, name-by-name director list for an arbitrary company today. Rather than silently falling back to a company-only check with no person-level signal at all, Gumshoe cross-references every entity against four other public registers that do carry named individuals: the ACNC charity register, the ASIC financial adviser register, state trade licence registers, and the Tax Practitioners Board register. When a run turns up a name in one of these registers who is also connected to a cancelled entity, or matches the ASIC banned persons register, that connection is surfaced.

The check runs two passes:

1. Phoenix pattern — an associate linked to a company cancelled in the last 36 months

Gumshoe checks whether anyone identified against this entity through the ACNC/adviser/licence/TPB registers is also linked, via the same registers, to another entity whose ABN was cancelled within the last 36 months. This is the hallmark of phoenix fraud: closing a company to shed debts and immediately re-opening under a new name. A confirmed real example: an entity linked to an adviser also linked to a company cancelled 14 months earlier surfaces here.

A FAIL result means a link was found. A PASS means no such link was found across the registers Gumshoe currently has access to — it does not mean no link exists anywhere, since ASIC's own director register isn't queryable live.

2. ASIC Banned & Disqualified Persons

Gumshoe cross-references every name resolved via the associate registers above — and the entity's own name — against the ASIC Banned & Disqualified Persons register (7,000+ entries). This register includes:

• People banned from managing corporations under s206F or s206EAA of the Corporations Act
• Directors disqualified following company failure
• People subject to court-ordered bans
• Individuals who have failed to pay a civil penalty

If a resolved associate name currently matches the banned register, the Phoenix tile will FAIL and show the ban type and effective date.

Court conviction records

Gumshoe provides one-click search links to the following databases for manual verification when a supplier warrants deeper investigation:

• ASIC Connect — full officeholder history, including historical roles and disqualifications (manual search only — see above)
• Federal Court judgments (AUSTLII) — searchable by party name; includes civil and criminal proceedings in federal jurisdiction
• ACCC enforcement register — competition and consumer law enforcement outcomes

These links appear in the expanded Phoenix tile for every company verification. They are pre-filled with the entity name so you can run the searches immediately.

Limitations

• The associate cross-check only surfaces a person if they appear on the ACNC, ASIC adviser, trade licence, or TPB register. A director who holds none of those roles is currently invisible to Gumshoe — this is a real coverage gap, not a design choice, and it exists because ASIC's own register can't be queried live.
• Sole traders and partnerships don't have ASIC company director records to begin with; the associate cross-check still applies to them via the same four registers.
• Australia does not maintain a publicly accessible, machine-readable national criminal conviction register. Court-level criminal records must be verified directly with courts or via an ASIC/police check service.

What to do with a FAIL result

A FAIL on the Phoenix check does not automatically mean you should not engage the supplier. Phoenix fraud is a serious concern, but some legitimate business restructures share the same pattern, and an associate-register match is a lead, not a confirmed director record. The recommended process:

1. Note the specific associate name, register, and cancelled-entity details shown in the tile
2. Ask the supplier directly about the closure or the individual's role
3. Search ASIC Connect manually for the deregistered company to understand the circumstances
4. If a banned-persons match is shown, do not proceed without independent legal advice