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AML Compliance for TCSPs

From 1 July 2026, trust and company service providers will be subject to AML/CTF obligations. TCSPs are considered particularly high-risk given their role in forming and managing corporate structures that can be misused for money laundering.

AML Shield provides comprehensive compliance solutions for TCSPs, helping you understand and meet your obligations.

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TCSP AML Compliance

Covered Services

Obligations apply when providing these services:

  • Forming companies, partnerships, or other legal entities
  • Acting as a director, secretary, or partner
  • Providing a registered office or business address
  • Acting as a trustee of a trust
  • Acting as a nominee shareholder
  • Arranging for others to act in the above roles

Key Obligations

What you need to comply with:

  • Develop a risk-based AML/CTF program
  • Perform thorough customer due diligence
  • Identify all beneficial owners
  • Understand purpose of structures
  • Monitor ongoing relationships
  • Report suspicious matters to AUSTRAC
Frequently asked questions

AML/CTF FAQ

Do trust and company service providers need AML/CTF programs?

Trust and company service work is generally captured through the accounting and legal professional-services framework when a practice provides designated services with a geographical link to Australia, such as shelf-company, body-corporate, legal-arrangement, nominee, or address services. AML Shield provides a platform for managing these higher-structure workflows.

What TCSP services are captured by Tranche 2?

Captured trust and company services in accounting and legal practices include selling or transferring shelf companies, assisting with the creation or restructuring of a body corporate or legal arrangement, acting or arranging for someone to act as a nominee director, secretary, partner, trustee, or nominee shareholder, and providing a registered office or principal-place-of-business address. For the broader Tranche 2 context, see what Australian businesses need to know about Tranche 2.

How should TCSPs verify beneficial ownership?

Accounting and legal practices providing trust or company services should identify the individuals who ultimately own or control client entities and trusts, verify information using reliable evidence, understand control chains, and update records when structures change. AML Shield helps keep entity, controller, and beneficial-owner evidence linked to the client workflow.

What AML records should TCSPs keep?

Accounting and legal practices providing trust or company services should keep records of CDD, beneficial ownership, risk assessments, purpose of structures, screening, suspicious matter escalation, staff training, and program governance for the required period. Training and documented processes are important because this work can involve complex structures.

How does AML Shield help TCSPs manage entity and beneficial-owner workflows?

AML Shield helps accounting and legal practices manage entity and beneficial-owner workflows by connecting client onboarding, structure mapping, risk assessment, screening, document evidence, training records, and audit trails. Review pricing or contact AML Shield to discuss your trust and company service model.

Ready to prepare your TCSP business?

Contact us to get started on your TCSP compliance program.