Profession-specific playbook Current
AML/CTF operating playbook for trust and company service providers
The trigger is the specific entity-management service, not the client relationship generally.
Trust and company service providers sit at the centre of AUSTRAC's Tranche 2 reforms because of the entity-control services they offer. This playbook sets out how the core AML/CTF obligations apply once captured. It is general information, not legal or compliance advice.
Action plan
1 Confirm which of your firm's entity-management services are AUSTRAC designated services Entity-formation and entity-control services are the core focus here -- check each service specifically.
AUSTRAC's AML/CTF reforms extend obligations to trust and company service providers offering specific designated services, including acting as or arranging directors, secretaries, trustees, or nominee shareholders, and providing a registered office or principal place of business address for an entity. Check each service your firm offers against AUSTRAC's own designated services guidance before assuming Tranche 2 does or doesn't apply.
- Review each entity-management service your firm offers against AUSTRAC's designated services guidance
- Don't assume administrative company-secretarial work is automatically outside scope
- Re-check this whenever your firm takes on a new entity-management role
Done when: Your firm's entity-management services have been checked individually against AUSTRAC's designated services guidance, not assumed
AUSTRAC: your AML/CTF obligations2 Appoint an AML/CTF compliance officer within 28 days of providing a designated service This clock starts from actually providing the service, not from enrolling with AUSTRAC.
Once your firm provides a designated service, AUSTRAC's guidance requires an AML/CTF compliance officer to be appointed within 28 days. Build this into your firm's Tranche 2 readiness plan as a hard deadline.
- Appoint an AML/CTF compliance officer within 28 days of first providing a designated service
- Confirm the appointee meets AUSTRAC's eligibility expectations for the role
- Document the appointment date to demonstrate the 28-day window was met
Done when: An AML/CTF compliance officer was appointed within 28 days of the firm first providing a designated service
See the AML/CTF compliance officer deep page3 Complete customer due diligence, including on beneficial owners, before starting the service For entity-management services, this includes identifying the beneficial owners behind the entity, not just the entity itself.
AUSTRAC's guidance requires initial customer due diligence to be completed before your firm starts providing a designated service to a client, with enhanced due diligence required where the client's risk is high or in other specified circumstances. For entity-management services specifically, this extends to identifying and verifying the beneficial owners behind the entity your firm is engaged to manage.
- Complete initial CDD, including beneficial ownership identification, before the designated service starts
- Escalate to enhanced CDD where the client's risk is high or another specified circumstance applies
- Keep evidence of when CDD was completed relative to when the service began
Done when: CDD, including beneficial ownership identification and escalation to enhanced CDD where required, was completed before the designated service began
See requesting beneficial ownership evidence for a corporate clientDesignated services
Entity roles
Acting as, or arranging, a director or secretary
Acting as, or arranging for someone else to act as, a director or secretary for a non-natural person is a service type worth checking specifically against AUSTRAC's guidance.
Entity roles
Acting as, or arranging, a nominee shareholder
Acting as, or arranging for someone else to act as, a nominee shareholder is a further entity-role service worth checking individually against AUSTRAC's designated services guidance.
Registered office
Providing a registered office or principal place of business address
Providing a registered office address, or principal place of business address, for an entity is another service type to review against AUSTRAC's own guidance rather than assuming it is purely administrative.