Trust and company service providers (TCSPs) — accountants, corporate-services firms, formation agents, nominee directors and registered-office providers — are one of the most-targeted Tranche 2 sectors in the Anti-Money Laundering and Counter-Terrorism Financing Amendment Bill 2024. From 1 July 2026, they sit fully inside AUSTRAC’s supervisory net.
The reasoning is straightforward: shell companies, opaque trust structures and nominee arrangements are the workhorse vehicles in modern money-laundering cases. The reforms close a gap Australia has been criticised for since 2015.
Who is caught
- Anyone forming or registering companies for clients
- Anyone acting as (or arranging) a director, secretary or trustee
- Anyone providing a registered office or business address
- Anyone acting as nominee shareholder or trustee
- Anyone providing trust set-up and administration services
What an AML/CTF program means
- Verify the identity AND beneficial ownership of every client (the human at the end of the chain)
- Risk-rate engagements (offshore beneficial owners, complex layering, PEPs)
- Ongoing CDD and trigger-based reviews when structures change
- Suspicious matter reports to AUSTRAC within 24 hours
- Seven-year record retention covering ID, structure charts and engagement files
- Annual compliance reporting plus a board-approved Part A program
What is new vs Tranche 1
Tranche 1 covered banks, casinos and money remitters. Tranche 2 brings in the gatekeepers — and TCSPs are the gatekeepers most cited in international laundering typologies. The practical lift is significant: beneficial-ownership checks down to ultimate human owners are not what existing client onboarding usually catches.
What contracts and documents need updating
- Engagement / service agreements — AML/CTF disclosure, ID and beneficial-ownership consent, source-of-funds clauses, refusal rights
- Trustee and nominee director appointments — additional due diligence and removal triggers
- Registered-office and mail-handling terms — termination triggers tied to AML risk
- Privacy notices — handling and storage of sensitive ID and structural data
- Subcontractor and referrer agreements — AML flow-down
The deadlines and penalties
Commencement 1 July 2026. AUSTRAC enrolment first; full Part A and reporting obligations from commencement. Civil penalties to $22 million per contravention for body corporates, with significant personal liability for principals.
How an updated Service Agreement helps
Claim Done’s Service Agreement generates a Tranche 2-ready engagement document in about ten minutes — AML/CTF disclosures, beneficial-ownership consent, source-of-funds clauses, the right to delay or refuse where checks fail, and the file-note structure AUSTRAC will expect at audit. Flat $79, DOCX and PDF.
Next step
Enrol, draft your Part A, re-paper engagement letters, and document beneficial-ownership checks before commencement.