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.
Need specialist support? Speak with our in-house team.
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.
This is a plain-English guide, not a determination of your status. If unsure, use the Am I in scope? guide or speak with us.
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.
Path 1
Self-managed
Run your AML program through Trancher using clear workflows and built-in guidance.
From $9.99 per week.
Path 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.
Path 3
Fully managed by our experts
Ask our experienced compliance specialists to manage agreed AML compliance activities on your business’s behalf.
Need specialist support? Speak with our in-house team.
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
Guides and articles for trust and company service providers
Questions from trust and company service providers
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. Many accountants and lawyers already do this work under another hat.
What are the deadlines?
[Answer needed — Tranche 2 commencement and enrolment timing]
What goes in the program?
[Answer needed — program content for a TCSP]
What does CDD look like in practice?
[Answer needed — CDD in practice for trust and company service providers]
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.
Ready to simplify compliance?
Book a short overview or speak with our in-house specialists about the right path for your firm.