For Trust & Company Service Providers

AML/CTF program for trust and company service providers — AUSTRAC Tranche 2

TCSPs sit at the centre of the structures used to obscure beneficial ownership — which is why AUSTRAC and the FATF treat the sector as inherently high-risk. From 1 July 2026 your business needs a fully operational AML/CTF program.

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Compliance Challenges for Trust & Company Service Providers

Forming companies, acting as nominee, providing registered office and administering trusts are all captured by Tranche 2. AutoAML drafts your full TCSP program in minutes.

Beneficial-ownership look-through is the whole point

The FATF mutual evaluation has flagged Australian TCSPs as a structural gap for years. AUSTRAC will expect your CDD to identify natural persons behind nominees, layered companies and offshore trusts — not just file the constituent documents.

Multiple designated services in one engagement

A single client engagement can include company formation, nominee director, registered office and trust administration — each a distinct designated service. Your program must cover all the lines of business you actually offer, not a generic template.

Foreign clients are routine, not exceptional

Most TCSP work involves cross-border structuring. PEP screening, jurisdiction risk-rating and enhanced CDD on high-risk countries are core day-to-day procedures, not edge cases.

Reputation risk reaches your bank as well as AUSTRAC

Australian banks de-risk TCSP clients aggressively when they can't see the program. A documented, AUSTRAC-aligned AML/CTF program is increasingly a precondition for keeping a business banking relationship, not just a compliance exercise.

What Trust & Company Service Providers Need for Compliance

The AML/CTF Act 2006 (Cth) and the AML/CTF Rules require all reporting entities to maintain these documents and procedures.

AML/CTF Program covering all designated services offered — s 81 of the Act

ML/TF Risk Assessment that distinguishes formation, nominee, registered office and trust services

Beneficial-ownership identification procedures at the 25 % threshold

Enhanced CDD procedures for foreign clients, PEPs and high-risk jurisdictions

Ongoing CDD with trigger-based reviews (change of director, change of beneficial owner)

SMR workflow with Compliance Officer escalation

Sanctions screening across DFAT and major international lists

7-year record retention per designated service (s 107)

Deadline & Applicability

Trust and company service providers — including formation agents, nominee directors, registered office providers and trust administrators — become reporting entities on 1 July 2026 under the AML/CTF Amendment Act 2024. The sector is on AUSTRAC's stated supervision priority list.

Last reviewed: 18 April 2026 · Information is general guidance, not legal advice.

How AutoAML Helps Trust & Company Service Providers

AI-Generated Documents

All 13 compliance documents drafted from your service mix and risk profile — Part A, Part B, risk assessment, CDD scripts, the lot.

Team & Audit Trail

Invite your team, assign Compliance Officer roles, and keep a tamper-evident audit log AUSTRAC supervisors can read.

SMR & TTR Built-in

Reporting workflows, training tracking, annual review reminders and document version control — so the program stays alive after day one.

Frequently Asked Questions

Trust & Company Service Providers & AUSTRAC: common questions

What counts as a 'trust and company service provider' for AUSTRAC?

Any business that, by way of business, forms companies or other legal persons, acts as a nominee director or shareholder, provides a registered office or business address, acts as trustee of an express trust, or administers a trust on behalf of others.

Do migration agents and accountants who occasionally form companies count?

If you provide the service 'by way of business' — even as a sideline — you are a reporting entity for that service. The AUSTRAC test is the activity, not the headline profession. Many accountants will be captured under both the accounting and TCSP categories.

How deep does beneficial-ownership identification have to go?

Down to the natural persons who ultimately own or control 25 % or more, plus anyone who exercises effective control regardless of percentage. For layered structures that means looking through every intermediate company and trust.

Can we rely on an overseas introducer's CDD?

Reliance is allowed under s 36A only if the overseas introducer is itself subject to equivalent AML/CTF regulation, has agreed to provide the underlying records on request, and the reliance is documented. The reporting entity remains liable for any deficiency.

What if a client refuses to disclose the ultimate beneficial owner?

You cannot complete the designated service. Refusal is itself a red flag and may warrant an SMR. Your Part B procedure should script how to terminate the engagement without tipping off.

Does our existing FATCA / CRS work satisfy AUSTRAC?

No. CRS and FATCA are tax-reporting regimes with different identification rules and lower beneficial-ownership thresholds. They overlap with AML/CTF but don't substitute for it — your AML/CTF records are a separate evidence trail.

Related industries under AUSTRAC Tranche 2

Many firms work across more than one designated-service category. Check the related sectors below.

For Lawyers

Stand up your TCSP AML/CTF program in 10 minutes

All 13 AUSTRAC-aligned documents drafted from your service mix. Free until the 1 July 2026 deadline.

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