Nominees, trusts, and the structures FATF watches closest.
TCSP services are designated under Tranche 2. From 1 July 2026, every company you form, trust you administer, and entity you act for is in scope — with beneficial-ownership rules tighter than any other Tranche 2 sector. AMLify gives you the programme, the UBO tooling, and the SMR workflow purpose-built for this work.
The Tranche 2 reality
What Tranche 2 means for TCSPs.
FATF has identified trust and company service providers as one of the highest ML/TF risk gateways globally — complex corporate vehicles, nominee arrangements, and discretionary trusts are the layering tools of choice. Australia's Tranche 2 reforms bring TCSPs into the AML/CTF Act 2006 in direct response.
From 1 July 2026, company formation, trust establishment, acting as nominee director or shareholder, and registered-office services are designated services. Your firm is a reporting entity with the same obligations as a bank — and the beneficial-ownership bar is higher than for any other Tranche 2 sector.
Why AMLify for trust & company services
Built for the way you actually work.
Nominee-aware UBO logic
Nominee directors and nominee shareholders are first-class fields. The UBO panel shows the legal owner, the underlying beneficial owner, and the nature of the nominee arrangement on one screen.
Multi-entity client view
A single client engagement covering 12 related entities is one customer record with 12 entities — not 12 silos. CDD refreshes propagate across the structure.
Trust-deed lifecycle aware
Settlor, trustee, appointor, and beneficiary changes trigger automatic re-screening. Discretionary-trust UBO rules match AUSTRAC's published guidance for the sector.
Tipping-off-safe escalation
SMR drafting happens in a restricted workspace. The customer-facing team continues normal service while compliance investigates — no leakage, full audit trail.
Your compliance obligations
What Tranche 2 requires for your business type.
- Customer due diligence on every settlor, trustee, beneficiary, director, and shareholder
- Beneficial-ownership identification and verification — including for nominee and layered structures
- Ongoing due diligence on all entities you administer
- Suspicious matter reporting to AUSTRAC within 3 business days (24 hours for terrorism financing)
- AML/CTF programme covering company formation, trust establishment, nominee, and registered-office services
- Staff training calibrated to TCSP-specific typologies (shell companies, nominee abuse, layering)
- Record keeping for a minimum of 7 years across every entity under administration
How AMLify helps
Purpose-built features for your industry.
- Ami builds a programme tailored to your service mix — formation only, full administration, or nominee work
- Beneficial-ownership workflows that handle nominee directors, nominee shareholders, and discretionary-trust UBO logic
- Per-entity CDD tracking — so a single client engagement covering 12 related entities doesn't become 12 spreadsheets
- FATF-aligned risk indicators baked into the risk-assessment wizard (complex structures, no commercial rationale, opaque ownership)
- Tipping-off-safe escalation workflow for SMR drafting, so the customer-facing team never sees a flagged matter
- Independent-review evidence file ready in one click for your annual AML/CTF Rule 8.6 review
Ask Ami
Examples of compliance questions you can ask your AI assistant.
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