Trust and company service providers (TCSPs) are one of the highest-risk Tranche 2 groups and are almost always reporting entities. Forming companies, providing registered offices, acting as nominee directors or trustees, and selling shelf companies are all designated services from 1 July 2026.
Because TCSP services are frequently used in layering and beneficial-ownership concealment, AUSTRAC expects robust customer due diligence and beneficial-ownership identification. Expect enhanced scrutiny where structures involve foreign parties or complex ownership.
Designated services for trust & company service providers
If you provide any of these, you're likely a reporting entity:
- 1Forming companies or other legal persons
- 2Acting as (or arranging) a nominee director, shareholder or trustee
- 3Providing a registered office or business address for a company
- 4Selling or transferring a shelf company or body corporate
- 5Managing client money, accounts, securities or other assets
What you'll need to do
- 1Enrol with AUSTRAC (enrolment opened 31 March 2026)
- 2Appoint an AML/CTF Compliance Officer
- 3Complete a money-laundering / terrorism-financing risk assessment
- 4Develop and maintain an AML/CTF program
- 5Carry out customer due diligence (KYC) and verify beneficial owners
- 6Monitor transactions and report suspicious matters, large cash transactions and international transfers
- 7Keep records for seven years and train your staff
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Check your exact obligations
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