AMLify's New TCSP Module: Built for 1 July 2026

AMLify has released a major update to its trust and company service provider (TCSP) compliance module, introducing five purpose-built features for the due diligence, programme, and reporting obligations that become mandatory under Tranche 2 of the AML/CTF Act 2006 on 1 July 2026. With 53 days remaining, the new tools give TCSPs everything they need to build a compliant AML/CTF programme, map beneficial ownership across layered structures, and automate the ongoing monitoring AUSTRAC expects — without starting from scratch.

What's new in AMLify's TCSP module?

This release adds five core capabilities tailored to the specific risk profile of trust and company service providers:

1. Beneficial ownership mapper — a visual tool that builds corporate and trust structure charts through to the ultimate beneficial owner (UBO) level, with automatic flagging when ownership thresholds or control indicators are met.
2. TCSP-specific CDD workflows — guided due diligence checklists built for each service type TCSPs commonly provide, including trust formation, company incorporation, nominee directorship, and registered office services.
3. Ongoing monitoring engine — automated PEP and sanctions screening on onboarded clients, with configurable alert thresholds and re-screening triggers tied to material changes in a client's structure.
4. AML/CTF programme builder — a TCSP-edition template aligned to Part 2 of the AML/CTF Act 2006, with a guided customisation flow that reflects your business's risk profile.
5. Suspicious matter reporting (SMR) workflow — a structured in-platform workflow that guides staff through identifying, documenting, and lodging SMRs with AUSTRAC, including a pre-submission compliance check.

Why do TCSPs need purpose-built compliance tools?

Trust and company service providers sit at the highest end of AUSTRAC's money laundering and terrorism financing risk spectrum. They create legal entities, hold assets on behalf of third parties, and can be used — wittingly or not — to obscure the true ownership of funds or property. The Financial Action Task Force (FATF) has consistently identified TCSPs as a key vulnerability in global anti-money laundering frameworks, and AUSTRAC's national risk assessments have flagged nominee and trust services as particularly exposed to misuse.

That risk profile means generic compliance software frequently falls short. A CDD checklist built for a remittance provider will not capture the layered ownership complexity that comes with a discretionary family trust, a corporate trustee, and an underlying company with multiple beneficial owners across different jurisdictions. AMLify's TCSP module was designed around these structures from the ground up.

How does the beneficial ownership mapper work?

When you onboard a new client in AMLify, the beneficial ownership mapper prompts you to build a visual entity tree. For each layer — trust, company, partnership, or individual — you record the relevant party, their role, and their percentage of ownership or control. The platform automatically highlights when a natural person meets the beneficial ownership threshold (25% or more of ownership or control, consistent with AUSTRAC guidance) and flags any chain where ultimate ownership cannot be confirmed.

The mapper integrates with AMLify's PEP and sanctions screening engine, so each beneficial owner identified in the tree is automatically screened against global watchlists at onboarding and re-screened whenever you update the structure. If a new director or trustee is added to a client's structure, AMLify triggers a screening event and logs the result — creating an auditable trail for AUSTRAC if your compliance programme is ever reviewed.

For TCSPs managing large client portfolios, the mapper's bulk upload function accepts structured data from common entity management platforms, reducing manual re-entry. Learn more about how these tools fit together on our features page.

Which TCSP services have dedicated CDD workflows?

AMLify's TCSP module includes purpose-built CDD workflows for the designated services that fall under Tranche 2:

• Trust formation and administration — captures settlor, trustee, protector, and beneficiary information, including verification requirements for discretionary beneficiaries.
• Company formation — records all founding directors, shareholders, and beneficial owners, with prompts for foreign company structures and jurisdictional risk flagging.
• Nominee director and shareholder services — includes nominee arrangement documentation, underlying principal disclosure, and ongoing monitoring triggers for changes to the principal's circumstances.
• Registered office and address services — a lighter CDD pathway appropriate for lower-risk address-only services, with automatic escalation to enhanced due diligence (EDD) where other risk factors are present.
• Trustee services for managed investment schemes — maps unit holders, responsible entities, and related-party structures.

Each workflow is mapped to AMLify's customer risk rating framework, so higher-risk clients or service types automatically escalate to the EDD module without requiring manual triage.

How does ongoing monitoring work for TCSPs?

Ongoing monitoring is one of the areas where TCSP compliance programmes most commonly fall short in regulatory reviews. Onboarding a client correctly is only the first step — under the AML/CTF Act 2006, reporting entities must monitor the ongoing relationship and keep customer information current.

AMLify's ongoing monitoring engine runs three layers of automated surveillance:

1. Scheduled re-screening — all clients are re-screened against PEP and sanctions lists on a configurable cycle (monthly by default, with higher-risk clients set to weekly).
2. Transaction pattern monitoring — for TCSPs that handle client funds, AMLify's rule-based transaction monitoring flags patterns consistent with structuring, rapid movement of funds, or activity inconsistent with the client's stated purpose.
3. Trigger-based review prompts — when you update a client's beneficial ownership structure or service type, AMLify automatically prompts a CDD review to confirm the risk rating remains current.

All monitoring activity is logged with timestamps and user records, supporting the documentation obligations AUSTRAC expects from regulated entities.

What does the AML/CTF programme builder include?

Every reporting entity under Tranche 2 must have a documented AML/CTF programme that satisfies the requirements of Part 2 of the AML/CTF Act 2006. For TCSPs, that programme must address the specific risks attached to entity formation, nominee services, and trust administration — a generic template will not meet the standard.

AMLify's programme builder includes a TCSP-specific template that covers:

• A money laundering and terrorism financing (ML/TF) risk assessment methodology calibrated to TCSP service types
• Customer acceptance policy and risk rating criteria
• CDD and EDD procedures aligned to AUSTRAC's customer due diligence rules
• Employee training obligations and delivery tracking
• SMR and threshold transaction report (TTR) lodgement procedures
• Independent review requirements and scheduling

The builder walks you through each section, prompts you to customise based on your specific services, and produces a formatted document ready for board or senior management sign-off. Once approved, the programme is stored in AMLify and version-controlled so you always have an auditable history of changes. See how the module fits a broader compliance setup on our TCSP industry page.

Key Takeaways

• AMLify has released a dedicated TCSP compliance module covering five capabilities: beneficial ownership mapping, TCSP-specific CDD workflows, ongoing monitoring, an AML/CTF programme builder, and an SMR lodgement workflow.
• The beneficial ownership mapper builds visual entity trees and automatically screens each UBO against PEP and sanctions lists at onboarding and on an ongoing basis.
• Purpose-built CDD workflows cover trust formation, company incorporation, nominee services, registered office, and managed investment trustee services — each mapped to a risk rating tier.
• The AML/CTF programme builder includes a TCSP-specific template aligned to Part 2 of the AML/CTF Act 2006, with version control and board sign-off tracking.
• With 53 days until the 1 July 2026 Tranche 2 deadline, TCSPs that have not yet started building their compliance programme should begin immediately to allow time for internal review and staff training.

Frequently Asked Questions

Q: When do TCSPs need to comply with Tranche 2 obligations?

The Tranche 2 amendments to the AML/CTF Act 2006 take effect on 1 July 2026. Trust and company service providers must have an operational AML/CTF programme, functional CDD procedures, and AUSTRAC reporting workflows in place by that date. AUSTRAC has not announced a transitional grace period for TCSPs, so full compliance is expected from day one.

Q: What is the beneficial ownership threshold for TCSPs?

Consistent with AUSTRAC guidance and FATF Recommendation 25, TCSPs should identify any natural person who owns or controls 25% or more of a customer entity — or who otherwise exercises effective control — as a beneficial owner requiring verification. For trust structures, this typically includes the trustee, settlor, protector, and any identified or identifiable beneficiaries.

Q: Does AMLify support Designated Business Group arrangements for multi-entity TCSPs?

Yes. AMLify supports Designated Business Group (DBG) arrangements, allowing related TCSP entities to share a single AML/CTF programme and compliance infrastructure within the platform while maintaining separate client portfolios and audit trails for each entity. This is particularly useful for corporate trustee and company administration businesses that operate through multiple related legal entities.

Q: How does AMLify's SMR workflow help TCSPs meet their reporting obligations?

When a staff member or automated monitoring alert identifies a potential suspicious matter, AMLify's SMR workflow guides the user through documenting the basis for suspicion, capturing supporting evidence, and completing the required AUSTRAC report fields. The platform applies a pre-submission compliance check before lodgement and retains a timestamped copy of every submitted report, supporting the record-keeping obligations under the AML/CTF Act 2006.

Q: How quickly can a TCSP get set up on AMLify before the 1 July 2026 deadline?

Most TCSPs can complete initial setup — including importing client data, configuring CDD workflows, and generating a draft AML/CTF programme — within a few business days using AMLify's guided onboarding process. With 53 days remaining, there is still enough time to stand up a compliant programme, but TCSPs should begin immediately to allow adequate time for internal review, board sign-off, and staff training before the deadline.

This is general information only and not a substitute for legal advice.

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