TCSP designated services in detail
AUSTRAC's TCSP designated services are central to Tranche 2 and cover the most heavily-typology-flagged AML risk areas. Company formation on behalf of a client, acting as a nominee director or shareholder, trust formation, managing client funds in trust, and certain forms of structuring all attract the full obligation set.
AU TCSPs cover a wide spectrum from sole-trader corporate-services boutiques to multinational corporate-services firms. The Act applies uniformly; smaller TCSPs do not face a reduced obligation set.
Risk patterns specific to TCSPs
AUSTRAC and FATF have both flagged TCSPs as elevated-risk because the designated services they provide are the primary mechanism for layering and obscuring beneficial ownership. AU TCSPs should expect particularly close attention to beneficial-owner capture, source-of-funds documentation, and ongoing monitoring of company and trust structures established for clients.
Practical implication: the customer-form configuration for a TCSP needs to capture beneficial owners down to natural persons at every layer of every structure formed. Caltury's customer form is built around this requirement.
How Caltury supports a TCSP
Caltury produces a Program tailored to a TCSP, with Part A explicitly addressing the elevated-risk profile and Part B covering deep beneficial-owner capture. The customer form branches by entity type and captures each natural person in the ownership chain. Sanctions and PEP screening runs against each natural person.
Time to live for a small TCSP is typically 8 to 12 hours over the 14-day trial because the customer-form configuration takes longer to tune for the depth of beneficial-owner capture. The Practice tier (A$249/mo) suits a 2 to 5 person TCSP; Firm tier (A$499) suits 6 to 15.
Common questions
Are corporate-services firms the same as TCSPs?
In substance, yes. The Act uses the designated services as the test, not the firm name or job title. Any firm providing company formation, nominee, trust setup or managed client money is a TCSP in the Act's sense regardless of how it markets itself.
How deep does beneficial-owner capture need to go?
Down to natural persons. If the company you form for a client is owned by another company which is owned by a third company which is owned by a discretionary trust, the natural-person controllers of that trust are captured. Caltury's customer form does not let you progress until each layer is recorded.
Do nominee director arrangements need additional documentation?
Yes. A nominee arrangement does not relieve the TCSP from identifying the underlying beneficial owners. The Program describes the firm's procedure for nominee engagements and the customer-form workflow captures the natural-person beneficial owners behind each nominee.
Can a TCSP also serve other clients without AML obligations?
If the TCSP's whole offering involves designated services, the firm operates entirely as a reporting entity. If the TCSP also provides services outside the designated set (general advisory, marketing, secretarial-only work without nominee), the Program describes which engagements are in and out of scope.
This page is general information about Australian AML/CTF obligations. It is not legal advice. AUSTRAC has not reviewed this content. For situations specific to your practice consult an Australian-qualified lawyer or AML/CTF adviser.