Do I still need a solicitor for AML/CTF Tranche 2 compliance?

Yes. HeadStart Docs products are digital publications that give you a substantial head start, but they must be reviewed and tailored by a qualified solicitor to your specific business circumstances before implementation.

How is HeadStart Docs different from the free AUSTRAC Starter Kits?

AUSTRAC Starter Kits are generic starting points that require significant customisation. HeadStart products are sector-specific, pre-populated with industry-relevant risk factors and scenarios, and include 12 months of AML Portal access for ongoing compliance including screening, record keeping and reporting tools.

What if the AML/CTF rules change after I purchase?

Your digital products are yours to keep. If significant regulatory changes occur, updated versions will be available to active portal subscribers. The AML Portal itself is continuously updated to reflect current AUSTRAC requirements and sanctions lists.

What happens after my 12-month AML portal access expires?

Your documentation is yours forever. To continue using the AML Portal (screening tools, compliance calendar, record keeping), you pay $35 per customer CDD. Cancel anytime — no subscription required.

Is HeadStart Docs a law firm?

No. HeadStart Docs is a digital publisher and platform provider. We sell digital compliance products and portal access. We do not provide legal advice. Referrals for legal advice can be made to our related law firm, HeadStart Counsel.

When does AML/CTF Tranche 2 commence in Australia?

Tranche 2 AML/CTF obligations commence on 1 July 2026. All reporting entities in designated sectors including lawyers, accountants, real estate agents, conveyancers, and trust and company service providers must have their AML/CTF programs in place by this date.

What AML/CTF documentation do nominee director services need?

Nominee Director Services need an AML/CTF program including: Ultimate Controller Identification, Purpose Assessment, Ongoing Monitoring. Our digital products provide a headstart on compliance documentation.

When does Tranche 2 commence for nominee director services?

Tranche 2 AML/CTF obligations for tcsp sectors commence from 1 July 2026. AUSTRAC enrolment opens from 31 March 2026. Businesses should begin preparing their AML/CTF programs now.

Home

Programs

Portal

Nominee Director Services

Name: HeadStart Docs
Brand: HeadStart Docs
Price: 679 AUD

Nominee director service providers are designated reporting entities as TCSPs under Tranche 2. Here's what you need to know before 1 July 2026.

New to Tranche 2? Read our comprehensive guide

Who is captured under Tranche 2?

Likely captured

Providers of nominee director services who allow their personnel to act as directors on behalf of third parties are likely to be captured under Tranche 2 as TCSPs. We recommend seeking legal advice to confirm your obligations based on your specific services.

Available Now: TCSP Edition

Free program documents

A headstart on AML compliance. Program documents tailored to nominee director services operations, from $249 one-time (or bring your own program). Your lawyer reviews and signs off before you go live.

A HeadStart on Compliance

Digital products to help you build your AML/CTF program, whether or not you are in scope

Ready-to-Customise Resources

Documentation tailored to your sector, ready to customise with your lawyer

Team Training

Staff training materials for your team and compliance officers

Key AML/CTF Areas for Nominee Director Services

Our documentation covers all critical AML/CTF compliance areas specific to your profession. Your lawyer reviews and tailors these to your business before you go live. We include a structured brief so the review is efficient.

Ultimate Controller Identification
Enhanced due diligence for who controls the company.
Purpose Assessment
Understanding why nominee directors are required.
Ongoing Monitoring
Continuous monitoring of company activities.
Instruction Verification
Verifying legitimacy of instructions from controllers.
Liability Awareness
Understanding director liability exposure.
Suspicious Matter Reporting
Heightened awareness of shell company indicators.

What's Included in Your TCSP Edition

Digital products tailored to nominee director services operations, ready to customise with your lawyer.

• AML/CTF program framework for nominee director services
• Risk assessment worksheet (ML/TF/PF risks)
• Controller identification procedures
• Purpose assessment protocols
• Ongoing monitoring procedures
• Instruction verification checklist
• Liability assessment procedures
• Suspicious matter reporting procedures
• Recordkeeping schedules
• Staff Training Register

Related Sectors:

Free Tools

Implementation TimelineKey dates and milestones for Tranche 2 compliance Readiness TestAssess your compliance readiness in 2 minutes Sanctions ScreeningSearch Australian sanctions lists and country risk

Related Resources

Related TCSP Professions

Company Secretaries Virtual Office Providers Online Incorporation Services Registered Agents

Disclaimer: This information is general in nature and does not constitute legal advice. HeadStart Docs™ provides digital products only, not legal services. Always seek advice specific to your circumstances from a qualified legal professional before implementing any AML/CTF program. We do not guarantee the accuracy of this information.