Form Companies or Manage Trusts for Clients? You're an AML/CTF Reporting Entity | TCSP Australia 2026

A lot of accountants, lawyers and corporate-services professionals read the Tranche 2 headlines, checked whether their main profession was captured, and moved on. Here's the catch many of them missed: trust and company service provider (TCSP) activities are captured separately under the professional-services designated services — and they may apply to you even if you'd already accounted for your "main" work.

Since 1 July 2026, if you provide one or more of these designated services — set out in section 6(5B), Table 6 of the AML/CTF Act — you're an AUSTRAC reporting entity for that work.

The services that quietly catch you

Table 6 targets specific TCSP designated services, including:

• Creating, or assisting to create, a company, trust or other legal arrangement for a client — setting up a discretionary trust, for example, is an item 6 service.
• Acting as — or arranging for someone to act as — a director, secretary, trustee, partner or nominee shareholder of a company or legal arrangement.
• Acting as a registered agent.
• Providing a registered office address or principal place of business address for an entity.
• Managing client money, accounts or assets in connection with these arrangements.

Read that list again with your own practice in mind. The corporate secretary who incorporates a couple of companies a month. The accountant who provides a registered office address for client entities. The adviser who arranges a nominee. Each is a designated service with AML/CTF obligations attached — and, as AUSTRAC notes, those obligations can arise during the preparatory steps, before any company is actually registered or any money moves.

"But my firm is already compliant"

That's the trap. Being captured for, say, your accounting or legal designated services doesn't automatically mean your TCSP activities are mapped, risk-assessed and covered. They're a distinct set of designated services with their own customer due diligence and beneficial-ownership expectations. Treating "we did AML" as a single tick is how firms end up with gaps exactly where AUSTRAC is most interested — the gatekeeper services that help create and run corporate structures.

Know exactly which obligations apply to you

The reformed regime carries a substantial set of obligations across enrolment (s 51B), the ML/TF risk assessment (s 26C), AML/CTF policies (s 26F), CDD, beneficial ownership, reporting and record keeping. Working out which ones bite on which of your services is the real work.

Veriqua's obligations register comes with all 45 AML/CTF obligations pre-loaded and mapped to your specific designated services. Instead of cross-referencing the Act against your service list by hand, you see — for company formation, for acting as a registered agent, for providing a registered office — precisely which obligations apply and where you stand against each one. It turns "are we covered?" into a register you can actually evidence.

Veriqua is a live, Australian-hosted compliance platform built for Tranche 2 entities. Two minutes, no login: demo.veriqua.com.au/start.