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

When you run a verification on a company (any entity with an ACN), Gumshoe retrieves the current director list from ASIC Connect in real time. It then runs three cross-checks:

1. Phoenix pattern — deregistered companies in the last 36 months

Gumshoe checks whether any director of the entity under review has also directed another company that was deregistered in 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 FAIL result here means a direct link was found. A PASS means no such link was found in the ASIC register data loaded into Gumshoe — it does not mean no link exists anywhere.

2. ASIC Banned & Disqualified Persons

Gumshoe cross-references every director against the ASIC Banned & Disqualified Persons register (7,153 current 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 any director is currently banned, the Phoenix tile will FAIL immediately and show the ban type and effective date.

3. Adverse records linked to directors

Enforcement records (from QBCC, NSW Fair Trading, ACCC, etc.) that are linked to individual director names — not just the company entity — are also surfaced in the Phoenix tile.

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
• 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 director cross-check only applies to companies (entities with an ACN). Sole traders and partnerships do not have ASIC director records.
• Director data is scraped live from ASIC Connect and cached for 30 days per company. The first time a company is verified, there is a brief delay while ASIC data loads.
• 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 a 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. The recommended process:

1. Note the specific company name and deregistration date shown in the tile
2. Ask the supplier directly about the closure
3. Search ASIC Connect for the deregistered company to understand the circumstances
4. If a director ban is shown, do not proceed without independent legal advice