Free AML Compliance for Trust & Company Service Providers

What is a Trust & Company Service Provider (TCSP)?

TCSPs are businesses that provide corporate administration services — forming and managing companies, trusts, and other legal entities on behalf of clients. Under AUSTRAC Tranche 2, TCSPs become reporting entities from July 1, 2026.

You're a TCSP if you provide any of these services:

✅ Company formation — incorporating companies, registering business names
✅ Trust formation — establishing discretionary, unit, or hybrid trusts
✅ SMSF setup — setting up self-managed super funds
✅ Acting as nominee director/shareholder — providing corporate directors
✅ Acting as corporate trustee — serving as trustee for clients' trusts
✅ Registered office services — providing business addresses
✅ Company secretarial services — ASIC lodgements, minute-taking

Penalties: Significant civil penalties set in penalty units. Directors face criminal prosecution (2 years jail). This is not optional.

⚠️ Why Are TCSPs High-Risk for Money Laundering?

TCSPs are FATF-identified high-risk because they create legal structures that can obscure beneficial ownership:

🚨 Layering — multiple companies/trusts make it hard to trace ultimate owners
🚨 Nominee structures — professional directors/shareholders hide real controllers
🚨 Offshore connections — mixing Australian + foreign entities
🚨 Shell companies — entities with no real business activity

This is exactly why AUSTRAC is targeting TCSPs in Tranche 2. You'll face higher scrutiny than most other reporting entities.

TCSP AML/CTF Obligations

1. Customer Due Diligence (CDD)

Verify every client requesting TCSP services. This includes:

Individual clients → government ID + biometric verification
Company clients → verify company + all beneficial owners (25%+ shareholders)
Trust clients → verify trustees + settlors + beneficiaries (if identified)

Try free customer verification →

2. Beneficial Owner Identification

This is the big one for TCSPs. You must identify and verify beneficial owners (UBOs) — individuals with 25%+ ownership or control.

For companies → extract shareholders from ASIC registers
For trusts → identify appointors, trustees with distribution power
For complex structures → trace through multiple layers to ultimate individuals

See entity verification tool →

3. Enhanced Due Diligence (EDD)

Higher-risk clients require enhanced checks:

PEPs (Politically Exposed Persons) — extra scrutiny + source of funds
Complex ownership structures (3+ layers)
Offshore entities (particularly tax havens)
Clients from high-risk countries (FATF grey/black lists)

4. Ongoing Monitoring

Re-verify customers periodically (12/24/36 months based on risk). Watch for changes in ownership, control, or business activity.

5. Suspicious Transaction Reporting

File a Suspicious Matter Report within 3 business days of forming the suspicion, and within 24 hours when the suspicion relates to terrorism financing. Common TCSP red flags are below.

File SMR report →

Free TCSP AML Toolkit

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Customer Verification

Biometric KYC for individuals + entity verification for companies/trusts. Instant results, built for AUSTRAC Tranche 2 CDD.

Start verification →

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Beneficial Owner Extraction

AI-powered UBO extraction from ASIC extracts, trust deeds, company constitutions. Identifies all 25%+ owners automatically.

Try UBO tool →

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AML Program Template

Board-ready AML/CTF Program for TCSPs. Covers entity formation, nominee services, offshore structures, EDD procedures.

Download program →

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Risk Assessment Generator

AI-powered ML/TF risk assessment for TCSP businesses. A report for your compliance file in about 5 minutes.

Generate assessment →

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AUSTRAC Reporting Tools

File SMRs, TTRs, IFTIs directly to AUSTRAC. Pre-filled forms, wizard interface, no paperwork.

File report →

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TCSP Training Courses

Free online training for TCSP staff. Covers UBO identification, shell company red flags, PEP screening.

Start training →

🚩 Red Flags for TCSPs

File a Suspicious Matter Report within 3 business days of forming the suspicion, and within 24 hours when the suspicion relates to terrorism financing, if you see:

✓ Client wants nominee directors/shareholders to hide real owners

✓ Complex multi-layered structure with no clear business purpose

✓ Client refuses to disclose beneficial owners or provides false info

✓ Offshore entity incorporated in tax haven (BVI, Cayman, Panama)

✓ Client changes ownership structure frequently to obscure control

✓ Entity has no real business activity (shell company red flag)

✓ Client requests backdated documents or false records

✓ Beneficial owner is a PEP or on sanctions list

✓ Entity involved in high-risk industries (crypto, gambling, adult content)

✓ Source of capital is unclear or inconsistent with stated purpose

Use our free SMR tool to report suspicious activity to AUSTRAC.

TCSP AML FAQ

Do I need to verify existing clients by July 1, 2026?

Yes. You must verify all clients receiving TCSP services — even long-standing ones — by the Tranche 2 start date. Use the transition period wisely.

What if the beneficial owner is another company/trust?

Trace through to individuals. AUSTRAC requires you to identify ultimate beneficial owners — real people, not entities. For complex structures, this may involve multiple layers.

Do I need to verify nominee directors I provide?

Yes. If you act as nominee director/shareholder, you must verify the real controller (your client instructing you). Your client is the beneficial owner, not the nominee.

Can I use FreeAML for offshore entity verification?

Partially. We verify Australian entities (companies/trusts/SMSFs) + Australian IDs. For offshore entities, you'll need foreign company extracts + enhanced due diligence. See entity verification guide.

How long is FreeAML free for TCSPs?

Core tools (KYC, entity verification, AML program, training) are free permanently. High-volume TCSPs (100+ verifications/month) pay $20/check (individual) or $40/check (entity). See pricing.