Registered office and company formation services and AML
Company formation and a registered-office service are AML questions because they may be professional designated services. “We only provide the address” is not the end of the question.
Quick answer
Ask whether this formation, or this registered office, is a designated service in your program, and write that service down if you sell it. Ordinary tax work is a different page. This page does not reproduce AUSTRAC’s professional services list. The client pays a check the program requires.
People search “company formation AML Australia” when a tax practice forms a company and provides its street address, and treats both as paperwork with no customer question. Checked against AUSTRAC’s professional designated services page on 4 October 2026. This is general information, not legal advice. This page does not reproduce that guidance. The wider accountant service test is designated services for accountants. Who you then identify on the company is the beneficial owner of a company. The sector map is /tranche-2.
Formation and the address are services
A tax practice often forms the company, holds the records, and lets the client use the practice address as the registered office. Each of those can be a service the AML/CTF regime cares about, depending on how the professional designated services are drawn. AUSTRAC’s page is the description. This page does not copy the list and does not tell you that your particular retainer is in or out.
Write the service you actually sell. “Shelf company”, “we incorporate”, and “use our address” should each have a line in the program: in scope or not, and why. A client who only wants the address is still a customer question if that service is designated.
- Name the product. Formation, registered office, and nominee roles are different products. A single line that says “company secretarial” hides which one you provide.
- Do not hide behind the tax file. The same client may have a tax return that is out of scope and a formation that is in scope. Split the files.
- The address is not a favour. If the program treats the registered office as a designated service, the customer is identified under that program. A mailbox number is not CDD.
- Then identify the people the program names. The company check and the individuals are separate. The beneficial-owner page is where that test lives.
What the practice is selling
Sort the invoice line before you sort the identity documents. The invoice is the clue to the service. The service is the clue to the program.
A sorting aid for a practice that forms companies. This table does not reproduce AUSTRAC’s professional designated services.
| What you sell | Program question | Common shortcut |
|---|---|---|
| Incorporate a company | Is formation a designated service for us | “It is only an ASIC form” |
| Registered office at the practice | Is providing that office in scope | “It is just an address” |
| Tax return for the same client | A different service, tested on its own page | Sweeping it in because you also formed the company |
| People behind the new company | Who the program says you identify | Stopping at the director who signed the form |
Where the formation page stops
This page is formation and the registered office. It is not the full accountant service list and it is not the beneficial-owner test. Those are designated services for accountants and the beneficial owner of a company.
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. Deciding that a formation is in scope is not included in the firm suite, and neither is the ASIC lodgement. Confirm the live amounts on FreeAML pricing. FreeAML does not decide that a formation or a registered office is a designated service.
📚 Related Resources
Accountant AML Toolkit →
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Free AML Program →
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Frequently Asked Questions
If the formation is in scope, the client pays the check.
The firm suite is A$0. The client pays. Use KYB for the company and KYC for each individual the program names.
Start an AML checkQuestions: team@freeaml.com.au