AMLify for TCSPs: New Features Before 1 July

AMLify's trust and company service provider (TCSP) compliance module covers the full Tranche 2 obligation set for Australian TCSPs — from the layered beneficial ownership mapping that defines TCSP risk, to nominee arrangement controls, enhanced due diligence workflows, suspicious matter reporting, and a guided AML/CTF programme builder calibrated to TCSP-specific risk factors. Now that Tranche 2 has commenced, here is what the module includes and how TCSPs are using it to get compliant before the cut-off.

What does AMLify's TCSP compliance module include?

The module covers every obligation a trust or company service provider faces under the Tranche 2 amendments to the AML/CTF Act 2006. Core capabilities include: - Guided Part A and Part B programme builder — walks the AMLCO through each required element, pre-loaded with TCSP-specific designated service categories including trust administration, company formation, nominee arrangements, and registered office services, producing a version-controlled programme document ready for senior management approval - ML/TF risk assessment — a structured tool that generates a documented risk assessment calibrated to the designated services TCSPs provide and the elevated inherent risk factors AUSTRAC associates with the sector - Layered beneficial ownership mapping — a guided workflow for tracing natural persons through multi-level corporate and trust structures, including structures involving foreign entities or nominee layers - Nominee arrangement risk controls — structured prompts for identifying, documenting, and periodically reviewing nominee director and nominee shareholder arrangements, with enhanced due diligence triggers for high-risk configurations - Enhanced due diligence (EDD) workflows — tailored EDD processes for politically exposed persons, complex structures, non-resident clients, and arrangements with unclear beneficial ownership - PEP and sanctions screening — integrated at onboarding and configured for periodic re-screening - AUSTRAC reporting — suspicious matter report (SMR) and threshold transaction report (TTR) workflows aligned to AUSTRAC format requirements, with tipping-off safeguards - Staff training module — structured AML/CTF training content for TCSP staff, with completion tracking and records built in - Ami AI assistant — AMLify's AI compliance copilot for TCSP-specific compliance questions in plain English

How does beneficial ownership mapping work for TCSPs?

Beneficial ownership mapping is the defining challenge of TCSP compliance. Trust or company service providers routinely administer structures involving multiple legal entity layers — a discretionary trust with a corporate trustee, a company with a holding company as the sole shareholder, or an international structure with foreign entities in the chain. Under the AML/CTF Act 2006, TCSPs must identify the natural persons who ultimately own or control each client relationship, which means tracing through every entity layer until a natural person is reached or an ownership threshold is established. AMLify's beneficial ownership tool provides a step-by-step structured interview that maps each entity layer, records the evidence underlying each identification, and prompts for enhanced due diligence where the mapping encounters an unclear or high-risk feature — such as a nominee shareholder, an overseas entity that cannot be independently verified, or a structure where control appears to be held differently from formal ownership. The completed ownership map is stored against the client record and linked to the CDD file, providing an auditable trail that demonstrates the TCSP's compliance with its identification and verification obligations.

How does AMLify handle nominee arrangement risk?

Nominee director and nominee shareholder arrangements are among the highest-risk features AUSTRAC flags for the TCSP sector. A nominee arrangement places a person's name on public registers on behalf of the actual beneficial owner — a legitimate service in many contexts, but one that creates opacity around true control and ownership that is frequently exploited for money laundering purposes. AMLify's nominee arrangement controls integrate directly into the CDD workflow. When a client relationship involves a nominee arrangement, the system prompts the AMLCO to: - Record the identity of both the nominee and the underlying beneficial owner - Obtain and verify a nominee agreement or equivalent documentation confirming the arrangement - Document the rationale offered for using a nominee, and assess whether it is consistent with the client's known business profile - Apply enhanced due diligence where the rationale is unclear, involves multiple nominee layers, or where the underlying beneficial owner is in a high-risk jurisdiction - Set a periodic review trigger so the arrangement is reassessed at defined intervals The decision trail created by this workflow demonstrates ongoing oversight of nominee relationships — an area AUSTRAC has indicated will be a focus of Tranche 2 supervision for the TCSP sector.

How does the AML/CTF programme builder work for TCSPs?

The programme builder guides the AMLCO through each required element of Part A and Part B using a structured interview pre-loaded with the designated service categories most common in the TCSP sector: trust administration, company formation, nominee directorship, and registered office services. The builder asks the AMLCO to confirm which services apply, provide firm-specific details, and review AI-drafted programme language, then produces a written programme document that names the AMLCO, sets out the customer acceptance policy, specifies CDD procedures calibrated to the TCSP risk profile, and documents the independent review schedule. Senior management approves the programme inside AMLify, creating a timestamped version record. Most TCSP practices complete the full programme build in 20 to 35 minutes. The module is pre-calibrated to the elevated inherent risk AUSTRAC attributes to the TCSP sector, so the programme reflects the actual risk environment rather than a generic DNFBP template. Now that Tranche 2 has commenced, starting a free trial now leaves enough time to have an approved programme in place before 1 July 2026.

Can TCSPs use AMLify alongside non-TCSP professional services?

Yes. Many businesses providing TCSP services also deliver broader advisory, legal, or accounting work that falls outside the Tranche 2 designated service categories. AMLify allows you to scope your programme to the designated TCSP services specifically, without applying CDD and monitoring overhead to the non-designated portions of the practice. This keeps compliance proportionate to the actual regulated activity while meeting the obligation under the AML/CTF Act 2006. If a client engages the firm for both designated and non-designated services, AMLify's onboarding workflow applies the full CDD process to the relationship once — covering the designated services — without requiring the firm to re-verify the same client for every matter. See the full capability set on the AMLify TCSP industry page.

Key Takeaways

• AMLify's TCSP module covers the full Tranche 2 obligation lifecycle — programme builder, ML/TF risk assessment, layered beneficial ownership mapping, nominee arrangement controls, EDD workflows, AUSTRAC reporting, and staff training
• Beneficial ownership mapping is structured for complex TCSP structures — tracing through corporate trustee arrangements, multi-layer corporate groups, foreign entities, and nominee configurations, with an auditable trail for each client
• Nominee arrangement controls provide documented oversight of nominee director and nominee shareholder arrangements — an area AUSTRAC has flagged as a supervision priority for the TCSP sector
• The guided programme builder generates a compliant Part A and Part B in under 35 minutes, pre-calibrated to the elevated inherent risk of the TCSP sector
• Get compliant now — start a free 14-day trial at /pricing to have an approved programme in place

Frequently Asked Questions

Q: How long does it take for a TCSP to set up AMLify?

Most TCSP practices complete the initial setup — confirming their service scope, generating a draft programme, and creating their first client CDD workflow — in a single session of 20 to 35 minutes. The guided programme builder handles the structural work; the AMLCO reviews the output and confirms firm-specific details. Programme approval by senior management can be completed in the same session using AMLify's built-in approval workflow. Now that Tranche 2 has commenced, even a practice that has not yet started can build, review, and approve a compliant programme well before 1 July 2026.

Q: Does AMLify work for sole-practitioner TCSPs?

Yes. AMLify is designed to be proportionate and works equally well for sole practitioners providing registered agent or nominee services and for larger trust administration businesses. A sole practitioner who is the firm's principal, AMLCO, and entire compliance function can complete the programme builder, approve it in their own name, and manage ongoing CDD without a dedicated compliance team. The Starter plan is priced for sole practitioners and small practices.

Q: How does AMLify handle EDD for high-risk TCSP clients?

AMLify's enhanced due diligence workflows are triggered automatically when a client relationship meets criteria defined in the programme — such as a PEP, a non-resident client, a complex or multi-layer structure, or a nominee arrangement with an unclear rationale. The EDD workflow prompts the AMLCO to collect additional documentation, assess the elevated risk, and make and record an approval decision before onboarding proceeds. Every EDD decision is stored with a timestamped decision trail, providing the records AUSTRAC expects to see if the relationship is later reviewed.

Q: Is there a discount for TCSPs subscribing now that Tranche 2 is live?

Yes. Our Compliance Kickstart offer gives any Australian business that starts a subscription by 31 July 2026 a 30% discount for the first six months (code KICKSTART30). Every plan includes a 14-day free trial with no credit card required, so TCSPs can generate a full draft programme and test the CDD and beneficial ownership workflows before committing. See /pricing for current plan details.

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

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