Trust and company service providers (TCSPs) are among the most heavily regulated entities under AUSTRAC Tranche 2. If you form companies, manage trusts, act as a trustee or provide registered office services, you are captured — and the compliance requirements are detailed.
What is a TCSP under AUSTRAC?
A TCSP is any business that provides any of the following services:
- Creating, managing or administering companies, trusts or partnerships on behalf of clients
- Acting as a trustee, director or nominee shareholder
- Providing a registered office address for a client
- Buying or selling business entities on behalf of clients
- Assisting in the creation of express trusts
Why TCSPs face heightened scrutiny
Complex legal structures — trusts within trusts, nominee arrangements, offshore entities — are commonly used to obscure beneficial ownership and launder money. AUSTRAC treats TCSPs as a high-risk sector because they create and manage the very structures that can be misused.
KYB obligations for entity clients
For every entity you create or manage, you must trace ownership to the ultimate beneficial owner — a natural person who owns 25%+ or exercises effective control. This means:
- For companies: verify all directors and shareholders with 25%+ ownership
- For trusts: verify the trustee, settlor, appointor and all beneficiaries (or beneficiary class)
- For layered structures: trace through each layer until you reach a real person
Ongoing monitoring obligations
Unlike many other Tranche 2 entities, TCSPs have ongoing monitoring obligations that are particularly demanding. You must re-verify clients when ownership structures change, when suspicious activity occurs, and at periodic intervals based on risk level.
AI-assisted document scanning for TCSPs
CompliDesk uses AI to read ASIC extracts, trust deeds and partnership agreements — automatically identifying directors, trustees, beneficial owners and their ownership percentages. This dramatically reduces the manual work involved in onboarding complex entity clients.
CompliDesk helps all Tranche 2 entities stay compliant.
Whether you're a lawyer, accountant, real estate agent, conveyancer or TCSP — CompliDesk guides you through every step of your AUSTRAC obligations. Sign up free today.
Sign up free todayRelated reading: KYC/KYB for companies & trusts · Customer due diligence explained · AML risk assessment guide · Frequently asked questions