Nominee director or trustee services as a designated service

People search “nominee director AML designated service” when a client asks the tax partner to be nominee director of a shelf company and the partner treats it as a signature, not a service. Checked against AUSTRAC's page on who and what is regulated on 4 October 2026. This is general information, not legal advice. This page does not reproduce that guidance. The service list to test against is Table 6 designated services. A yes-or-no path is the Tranche 2 designated services decision tree. The sector map is /tranche-2.

A signature on the consent is a service

Accountants are asked to be the director clients can name, the trustee on a deed, or the shareholder who holds shares for someone else. The request is often framed as paperwork that sits beside the tax job. The regime does not use that frame. You are a reporting entity because of a designated service, not because the word accountant appears on your registration.

Hold this question apart from client money. You can be a nominee director and never see a dollar, and you can hold client money without being anyone's director. Each is its own test. A partner who is already on six shelf companies should list those roles before describing the practice as returns-only.

• Write the role in plain words. Nominee director, nominee shareholder, trustee, or registered office. 'Helping out' is not a service description.
• Separate it from the tax invoice. The fee can be buried in the annual bill and the service can still be there.
• Do not borrow the client-money answer. Touching funds is a different trigger. A quiet directorship is this one.
• List live roles. A consent signed last year is still a role if you have not resigned.

Roles a tax practice should list

Where the nominee-role page stops

This page is the nominee or trustee role as a possible designated service. It is not the full table and it is not the decision tree. Use Table 6 designated services and the Tranche 2 designated services decision tree.

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. Accepting a nominee role is not a KYC product, and the customers that role then requires you to know are still checked client-pays. Confirm the live amounts on FreeAML pricing. FreeAML does not decide that a nominee directorship or trusteeship is a designated service.

Frequently Asked Questions