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Compliance
October 4, 20269 min read

Multiple trust accounts across offices

Multiple trust accounts across offices are still one firm’s records. A receipt in the second account is not outside the program because the compliance officer sits somewhere else.

Quick answer

List every trust account the firm operates, including the suburban branch. Say in the program who can see each receipt and who tells the compliance officer. Do not assume head office is a complete picture. This page does not decide which receipt is reportable; it stops a second account from being forgotten.

People search “multiple trust accounts AML” when the firm has a trust account in each office and only the head-office ledger is on the compliance officer’s list. Checked against AUSTRAC’s threshold transaction report page on 4 October 2026. This is general information, not legal advice. This page does not reproduce that guidance. A single trust account’s filing question is trust account cash: who files. The threshold article is the threshold transaction report. The sector map is /tranche-2.

Head office is not the whole firm

Multiple trust accounts AML becomes a gap when a city firm opens a branch and the new trust ledger never reaches the compliance officer. The branch manager knows the account. The program still names one account, opened years ago, at the main office. A cash receipt in the branch is then nobody’s event; the client does not care which general ledger you prefer.

Write the list. Each trust account, each office, the person who reviews it, and how an odd receipt reaches the officer. This page does not say a receipt is reportable, and it does not appoint a filer. AUSTRAC’s threshold page and the who-files article do that work; record keeping in the program is the writing page; none of those are reproduced here; A two-office firm that cannot name its accounts on one sheet is not ready to claim it monitors them.

  • List every account. Branch, suburban, and main. An account that is not on the list is a blind spot.
  • Name a reviewer for each. The officer does not have to key every receipt. Someone must be responsible for showing them.
  • One escalation path. A branch oddity uses the same internal path as head office. A local workaround is how reports get lost.
  • Do not merge the ledgers to hide the count. Combining worksheets is not the same as seeing each account.

What the program should be able to name

A multi-office trust-account sort. This table does not reproduce AUSTRAC’s reporting rules.

FactWrite it downGap if you do not
Two trust accountsBoth account names and officesThe branch receipt is invisible
Who reviews the branchA named personThe manager assumes head office watches
How the officer hearsThe same escalation pathA local notebook
Whether a receipt is reportableOpen the threshold and who-files pagesA guess in this article

Where this page stops

This page is the second-account blind spot. It is not how the program is written. That page is the AML/CTF program for Tranche 2.

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. Monitoring a second trust account is not included in the firm suite. Confirm the live amounts on FreeAML pricing. FreeAML does not treat a second trust account as out of view or file reports for it.

Frequently Asked Questions

Every office’s customer check is still client-pays.

The firm suite is A$0. The client pays KYC or KYB. An extra trust account does not bundle those checks.

View pricing

Questions: team@freeaml.com.au