Without knowing the specific rules/clause, in essence the...

Without knowing the specific rules/clause, in essence the company is not responsible for collating 5+% announcements, as (quite rightly) the company cannot know the links between various brokerage accounts. As an example, I have two brokerage accounts, therefore two holding parcels, and while mine is an obvious one for the company to realise (because they are both in my personal name), it becomes impossible to know who to aggregate if I start using several different brokers as nominees, or a bunch of different $2 shell companies to hold my shareholding.

Therefore, according to ASX/ASIC, the onus is on the buyer to self report when they are over 5%, and their movements thereafter, until they drop under 5% again. If the buyer chooses not to, and has several different accounts, it would be very hard to police them. Of course, most large buyers from funds/instos are going to self report, because their relatively large holding in a single company (like KNL) is still likely to be a relatively small portion of their portfolio, and they are highly unlikely to choose to run foul of reporting rules merely to hide their involvement in one of their minor investments. That said, mistakes do happen, and while I can't think of any off the top of my head, I have seen 3Bs issued for other companies well after the fact, as various buyers have realised belatedly that they held over 5%. I'm pretty sure no-one went to prison for that though. I'm pretty sure you'd only risk prison if you were part of a systematic plan to purposely hide your interest for the purposes of defrauding someone (whether the company, or other shareholders).