AML for financial advisers who also do entity work
A financial adviser who also sets up companies or trusts has two AML questions. The advice may already be a designated service under the existing regime; the entity work may be a professional designated service under the reforms.
Quick answer
Split the engagement letter. Do not assume an advice AFSL relationship covers establishing a company or a trust. Do not assume entity work is new if the advice itself was already designated. The map of services is the table 6 page; this page only sorts the adviser who does both; the firm suite is A$0; the client pays the check the in-scope service requires.
People search “AML for financial advisers” when an adviser who has long given product advice is now establishing a company or a family trust for the same client. Checked against AUSTRAC’s page on who and what we regulate on 4 October 2026. This is general information, not legal advice. This page does not reproduce that guidance. The service map is table 6 designated services. A note aimed at financial-services firms is Tranche 2 for financial services. The sector map is /tranche-2.
Advice and entity work are not one file
Many advice firms have lived with AML/CTF for years because a designated service sat inside the advice. Tranche 2 does not invent that history. It adds a second question when the same firm establishes or restructures a company or a trust for the client.
That entity work can be a professional designated service even though the advice relationship is old. Writing both jobs on one engagement line is how the new service hides inside the old one.
- Name the advice. If it is already a designated service, the existing program still applies to it.
- Name the entity work. Forming or restructuring a company or trust is a separate sentence in the scope.
- Do not inherit enrolment. Being enrolled for advice does not silently enrol a new service you have not assessed.
- Match the check to the customer. A person is KYC. The company or the trust is KYB, then the people the program names.
Two columns on the engagement
An adviser who also does entity work. This table does not reproduce AUSTRAC’s designated-services tables.
| Work | The AML question | A collapse to avoid |
|---|---|---|
| Financial product advice already in regime | Keep the existing designated-service treatment | Calling all of it new because of Tranche 2 |
| Establishing a company | Is this a professional designated service? | Folding it into the advice file with no sentence |
| Establishing or varying a trust | Same question, trust customer due diligence if yes | A deed in the advice folder and no roles identified |
| Ordinary advice that is not designated | Out of scope | A check on every review meeting by habit |
Where the adviser page stops
This page is the adviser who does both advice and entity work. It is not the full designated-services map, and it is not a financial-services software note. Those are table 6 designated services and Tranche 2 for financial services.
What the client pays
On FreeAML the firm suite is A$0. The firm emails the client a link. Verification is client-pays. On the public list a personal KYC check is A$20 and a company or trust KYB check is A$40. Use KYB when the customer is a company or a trust. An advice relationship is not included in the firm suite, and it does not pre-pay KYB on a new entity. Confirm the live amounts on FreeAML pricing. FreeAML does not decide which of an adviser’s services are designated.
📚 Related Resources
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Frequently Asked Questions
Split the engagement before you send one link.
The firm suite is A$0. The client pays the check for the service that is in scope. The firm emails the link.
Open the Tranche 2 guideQuestions: team@freeaml.com.au