Trust and company service providers
AML/CTF for trust and company service providers
Creating entities, selling shelf companies, acting as a nominee and providing registered office addresses can all be designated services.
Trust and company service providers sit at the centre of AUSTRAC's professional designated services guidance, because entities can be used to hide who really owns or controls assets. The guidance covers creating or restructuring companies, trusts and other legal arrangements, selling shelf companies, assisting with the sale or transfer of control of an entity, and acting as, or arranging for someone to act as, a director, secretary, trustee, partner or nominee in specified circumstances.
Providing a registered office or principal place of business address in place of the client's own operational address can also be a designated service. AUSTRAC notes this applies even if you provide the address for free.
Beneficial ownership is the core risk. A beneficial owner is an individual who ultimately owns 25% or more of the customer, or who otherwise controls it. Control is not limited to the 25% test: an appointor of a trust, a person who can remove directors, or a person who gives instructions behind a nominee can be a beneficial owner with no shareholding at all.
If you provide these services, your obligations have applied since 1 July 2026. Changes in ownership or control are a natural trigger to review your records.
Scope
What is and isn't usually in scope.
Services that can be designated services
- Creating or restructuring a company, trust or other legal arrangement
- Selling shelf companies
- Assisting with the sale or transfer of control of a body corporate or legal arrangement
- Acting, or arranging for someone to act, as a director, secretary, trustee or nominee in specified circumstances
- Providing a registered office or principal place of business address in place of an operational address, even for free
Not automatically captured
- General advice about structures that does not take active steps to create or restructure an entity
Check AUSTRAC's guidance for the exact criteria and any exceptions for each service. Not sure? Try the readiness checker.
Example workflow
A practical onboarding sequence.
- 1
Map the structure first
Draw the ownership and control chain before you create or change anything.
- 2
Identify every beneficial owner
Include anyone who ultimately owns 25% or more, and anyone who otherwise controls the entity, whatever their shareholding.
- 3
Run entity and owner checks
Start an InvestPass entity check and add each beneficial owner for an individual check.
- 4
Confirm who is instructing you
Verify anyone acting on the customer's behalf and their authority, especially for nominee arrangements.
- 5
Escalate PEP and sanctions issues
Apply enhanced due diligence where required. Do not proceed on a potential sanctions match.
- 6
Review on change
Recheck when ownership or control changes, and keep records for the required periods.
This is an example only. Adapt it to your own AML/CTF policies.
Identity check vs program
A check is one step, not the whole job.
An InvestPass check helps with one part of customer due diligence: verifying identity and gathering ownership details. It does not by itself make you compliant. You still need your ML/TF risk assessment, AML/CTF policies, a compliance officer, PEP and sanctions handling, ongoing due diligence, reporting and record keeping. AUSTRAC states that a digital identity check alone is not full AML/CTF compliance.
When to check
Moments that usually need a check.
- Registering a company or trust for a client
- Acting as a nominee director, secretary or trustee
- Providing a registered office or business address
- Changes to who owns or controls an entity
Company check
Company details, directors and owners, with each owner checked.
Trust check
Trust deed, trustee and the people who control or benefit.
Owner checks
Individual checks for each beneficial owner: anyone who ultimately owns 25% or more, or who otherwise controls the entity.
Good to know
Tips for your team.
- Recheck when ownership or control changes.
- Keep entity and owner reports together for easy review.
General information only, not legal advice. Check your own obligations with AUSTRAC guidance or a qualified adviser.
Pricing
Pay per check. No monthly fee.
Individual Verification
FeaturedIndicative, to be confirmed
$20per person · GST included
Identity and AML screening for one person.
- Identity verification
- ID document and liveness
- PEP, sanctions and watchlists
- Risk assessment
Entity Verification
Indicative, to be confirmed
$40per entity · GST included
Company, trust or SMSF verification.
- ABN / ACN and business details
- Directors, trustees and shareholders
- Trust deed collection
- Entity screening
Beneficial Owner Verification
Indicative, to be confirmed
$20per owner · GST included
Each beneficial owner of an entity: owns 25% or more, or otherwise controls it.
- Identity verification
- PEP and sanctions screening
- Linked to the entity report
Indicative, to be confirmed. Prices in AUD, GST included.
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