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Guide
14 October 20269 min read

A TCSP label does not enrol you. The designated service does

AML for a trust and company service provider follows the service you provide, not the words on your website. Table 6 of the AML/CTF Act is the list. If you provide one of those services in the course of a business, Tranche 2 can apply. If you do not, the label does not enrol you.

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AML for Company and Trust Service Providers (TCSPs)

Quick answer

Trust and company service provider is a description of work, not a box that enrols you. Table 6 of section 6 of the AML/CTF Act lists professional designated services. If you provide one of those services, in the course of carrying on a business, and the geographical link is met, that service is what brings you in. Refusing the TCSP label does not take you out. Using the label does not put you in.

You may form companies, keep a registered office, sit as a nominee, or only do one of those things. Checked against AUSTRAC's professional designated services guidance and the AML/CTF Act on legislation.gov.au on 14 October 2026. This is general information, not legal advice. This page does not reproduce that guidance or table 6. A nominee shareholder row has its own page at nominee shareholder CDD. An address you lend to a company is registered office service. Acting as secretary is the company secretary designated service. Who you look through to is a beneficial owner. The sector map is /tranche-2.

The Act regulates the service

AUSTRAC's guide overviews table 6 of subsection 6(5B). The new designated services commenced on 1 July 2026. The rows people usually mean by TCSP work include selling or transferring a shelf company, helping create or restructure a body corporate or legal arrangement, acting or arranging a director, secretary, partner, or trustee of an express trust, acting or arranging a nominee shareholder, and providing a registered office or principal place of business address. Nearby rows cover a sale or transfer of a body corporate or legal arrangement, and equity or debt financing. This page does not copy the table, and it does not decide your row.

AUSTRAC says restructuring in the creation row means a change of legal form, such as a merger or demerger, not a staffing change. A filing agent is not, by that fact alone, in a nominee-role row. The address row is an address used in place of where the entity operates, and AUSTRAC describes it as a physical street address rather than a post office box. Exclusions AUSTRAC states include a power of attorney for an individual, testamentary trusts, and trusts not created in writing. Read the row before you rely on this paragraph.

Who the customer is can be wider than the person who emailed you

The customer column changes with the row. Creating a company brings in the person giving instructions and the beneficial owners and directors. Creating an express trust brings in the trustee, the settlor, and the beneficiaries, with the person instructing you. For a director, secretary, partner, trustee, or nominee shareholder role, AUSTRAC describes the customer as the nominator. A shelf-company sale looks to the buyer or transferee. An address looks to the person you provide it to. This page does not reproduce every cell. Open the guide for your row.

  • Start from the service, not the letterhead. A law firm, an accounting practice, and a formation shop can provide the same row.
  • Look through the new entity. Creating a company puts beneficial owners and directors on the customer side. An invoice is not that check.
  • The nominator is the point of a nominee role. The name on the public register may not be the person your program has to know.
  • An address can be the designated service. Lending your street address as a registered office can be the row, not a favour outside the Act.
  • Exemptions are written down. AUSTRAC notes some, including legal aid commissions, community legal centres, and barristers acting for Australian government bodies. Do not assume a private practice has them.

TCSP-type work, in the language of the service. This table does not reproduce table 6.

Work you might recogniseWhere AUSTRAC points youWhat you do not assume
Forming a company or an express trustThe creation or restructuring row, including preparatory steps the guide describesThat a staffing restructure is the same row
Selling a shelf companyThe shelf-company row, customer being the buyer or transfereeThat the company has no people behind it
Nominee director, trustee, partner, or nominee shareholderThe rows for acting or arranging those roles, customer being the nominatorThat a filing agent is automatically in those rows
Registered office or principal place of businessThe address rowThat a post office box is the address AUSTRAC describes

If you provide a designated service, the Act and the Rules still require enrolment, an AML/CTF program, a compliance officer, training, a risk assessment, initial customer due diligence before you commence, ongoing due diligence, and reporting. Section 28 is a civil penalty provision. How a suspicion is lodged is the suspicious matter report for Tranche 2. This page does not restate the clocks or the geographical-link test. A service that is not designated does not enrol you because a client used the TCSP label. Enrolment sits on AUSTRAC Online. FreeAML does not enrol you, and it does not lodge your report.

Where this page stops

This page is the service, not the job title. The address row is registered office service. The shareholder row is nominee shareholder CDD. Why a FATF statement is a separate country-risk question is the grey list and Australia's reforms.

What your client pays

FreeAML is a full AML/CTF platform for firms of every size. On FreeAML you pay $0 for the suite. There is no subscription. Your client can pay, and you can add a per-verification service charge. Verification is client-pays. On the public list a personal KYC check is $20 and a company or trust KYB check is $40. Confirm the live amounts on FreeAML pricing. FreeAML does not decide that your service is designated, and it does not identify the nominator for you.

Frequently Asked Questions

Look through the entity to a person.

FreeAML is an AML/CTF platform for firms of every size. You pay $0 for the suite. Your client pays $20 for KYC or $40 for KYB, and you can add a per-verification service charge.

See beneficial owner checks

Questions: team@freeaml.com.au