Tranche 2 · TCSPs
AML compliance for trust and company service providers
TCSPs that form companies/trusts, provide registered offices, or act as director, trustee or nominee shareholder provide designated services and are reporting entities. High formation and ongoing administration volume means efficient, repeatable workflows are essential.
Am I captured?
If you form companies or trusts, provide a registered office, or act as director, trustee or nominee shareholder, you provide designated services.
Designated services include:
- Forming companies, trusts or similar entities
- Acting as or arranging a director, secretary, partner, trustee or nominee shareholder
- Providing a registered office or accommodation address
- Managing or administering an entity on an ongoing basis
Many accountants and lawyers already do this work under another hat.
Your obligations
If you provide a designated service, you are a reporting entity. You must enrol with AUSTRAC, run a risk-based AML/CTF program, identify and monitor clients, keep records and report when the law requires it. Volume is the issue. Each new entity and each person behind it needs identification, and the file has to stay current when control of the entity changes.
AUSTRAC enrolment
Enrol with AUSTRAC and keep the enrolment current — including nominating a Compliance Officer. Enrolment is how AUSTRAC knows you are a reporting entity and how it contacts you.
Risk assessment
Document how your firm could be used for money laundering or terrorism financing — clients, services, delivery channels and geography — and keep that assessment current as the practice changes.
AML/CTF program
Put in writing how the firm will meet its AML/CTF duties: who does what, how clients are identified, how higher-risk work is handled, how staff are trained and how you will check the program still works.
Customer due diligence
Identify the client (and beneficial owners where relevant), verify that identity, screen for PEPs, sanctions and adverse media, and apply extra checks when risk is higher. Repeat when circumstances change.
Reporting
Submit suspicious matter reports to AUSTRAC when you form a suspicion, and any other reports that apply to your services. Do not tip the client off that a report has been made or is being considered.
Record-keeping
Keep the program, risk assessment, identification records and transaction records for at least seven years so you can show AUSTRAC what you did and why.
How Trancher helps
Program and risk assessment tailored to TCSP activity, streamlined entity and individual verification, clear audit trail across multiple entities and staff training.
Risk assessment and AUSTRAC-aligned program builder
Client verification (KYC/KYB) with PEPs, sanctions and adverse media screening
Ongoing monitoring and risk scoring
Reporting support (SMRs)
Staff training modules
Audit-ready records and dashboard
Three clear paths
Choose the level of support that works for your business — manage compliance yourself, add expert support when you need it, or have agreed activities managed for you.
1
Self-managed
Run your AML program through Trancher using clear workflows and built-in guidance.
From $9.99 per week.
2
Self-managed + expert support
Use the platform day to day and bring in our compliance specialists when you need help with set-up, risk assessment, program development, onboarding, training or first files.
3
Fully managed by our experts
Ask our experienced compliance specialists to manage agreed AML compliance activities on your organisation’s behalf.
How long does it take?
Most firms move from start to operational compliance within weeks.
Days 1–7
Enrolment and risk assessment underway
Days 8–21
Workflows live and team trained
Thereafter
Fully operational and audit-ready
Articles for trust and company service providers
2026 Tranche 2 AML Guide for Australian TCSPs
What if the 1 July 2026 deadline wasn’t a looming threat to your firm’s productivity, but the catalyst for its most significant operational upgrade?…
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Tranche 2 Obligations: 2026 AUSTRAC Readiness Guide
What if the 1 July 2026 deadline wasn’t a threat to your firm’s productivity, but the catalyst for a more profitable advisory model? We know that…
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What Happens During an AUSTRAC Audit? Guide for SMEs
An AUSTRAC audit is not a regulatory “gotcha” moment designed to catch you out. It’s a structured systems check to ensure your firm’s integrity…
View article →Questions from trust and company service providers
Am I captured?
Trust and company service providers are captured when they provide designated services such as creating, operating or managing companies or trusts; acting as or arranging directors, secretaries, partners or trustees; providing a registered office; or related corporate administration services. The trigger is the service provided, not the label of the business.
What are the deadlines?
Tranche 2 obligations commenced on 1 July 2026. Businesses already providing designated services on that date needed to enrol with AUSTRAC by 29 July 2026. If you start providing a designated service later, enrol within 28 days of first providing it. Nominate an AML/CTF Compliance Officer and keep your enrolment current.
What goes in the program?
Your AML/CTF program must include a written risk assessment and the controls tailored to the company and trust services you provide. This typically covers client and beneficial owner identification, PEPs/sanctions/adverse media screening, ongoing monitoring of higher-risk structures, suspicious matter reporting, staff training and record-keeping that demonstrates who controls the entities you form or administer.
What does CDD look like in practice?
Identify the client and beneficial owners, verify identity from reliable sources, and screen for PEPs, sanctions and adverse media. For company and trust work this includes understanding ownership and control structures. Enhanced checks apply where risk is higher (complex structures, higher-risk jurisdictions or clients). Records must show who was identified and why.
How is KYC/KYB charged?
Every verification check triggers one transaction. If you are identifying individuals within an entity (for example directors, beneficial owners or authorised persons), each individual check is a separate transaction and is charged accordingly.
Disclaimer
This is a plain-English guide only and is not a determination of your firm’s status. Whether you are a reporting entity depends on the specific designated services you provide, the facts of each engagement, and the applicable items in the AML/CTF Act. If unsure, use the Am I in scope? guide or seek independent legal advice. Trancher does not provide legal advice.
Ready to simplify compliance?
Book a short overview or speak with our in-house specialists about the right path for your firm.