Updated: January 2026
No AUSTRAC Starter Kit Available for TCSPs
AUSTRAC has not released a starter kit for Trust and Company Service Providers. TCSPs will need to source documentation from alternative providers or develop their own program.
No AUSTRAC starter kit for TCSPs: What you need to know
While AUSTRAC released official starter program kits for five Tranche 2 sectors in January 2026, Trust and Company Service Providers (TCSPs) are a "gap sector" with no free government resources available.
Why no AUSTRAC kit for TCSPs?
AUSTRAC's starter kits were released for sectors where the regulator identified a clear need for standardised starting resources. The five sectors with kits are:
- Legal Professionals (51 documents)
- Accounting Professionals (39 documents)
- Real Estate Agents (40 documents)
- Conveyancers (49 documents)
- Precious Product Dealers (36 documents)
TCSPs, along with Property Developers, Insolvency Practitioners and Business Brokers, were not included in the initial release. AUSTRAC has not indicated whether kits for these sectors will be released in the future.
Which TCSP activities are in scope?
Under Tranche 2, TCSPs become reporting entities when providing designated services including:
- Company formation and registration services
- Acting as or arranging for director, secretary or partner positions
- Providing registered office or business address services
- Acting as trustee or arranging for someone to act as trustee
- Acting as or arranging for nominee shareholders
What this means for TCSPs
Without an AUSTRAC starter kit, TCSPs have three main options for developing their AML/CTF program:
1. Develop your own program
Create documentation from scratch based on the AML/CTF Rules and AUSTRAC guidance. This requires significant time, effort and ongoing maintenance.
2. Engage a consultant
Hire an AML/CTF consultant to develop your program. This can be costly and may still require you to manage ongoing maintenance.
3. Use a free program solution
Get free comprehensive program documents designed specifically for TCSPs. This provides ready-to-use documentation with ongoing updates and support.
Key considerations for TCSPs
Unique TCSP risk factors
- 1
Complex beneficial ownership:
TCSPs often deal with layered corporate structures requiring detailed beneficial ownership verification procedures
- 2
Shell company risks:
Higher inherent risk of services being misused for money laundering requires robust red flag identification
- 3
Ongoing monitoring:
Changes in ownership and control of client structures need continuous monitoring procedures
- 4
International elements:
Cross-border structures and offshore entities require enhanced due diligence procedures
Next steps for TCSPs
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Disclaimer: This article is general information only. It is not legal, financial or compliance advice. HeadStart Docs™ provides free compliance documents, not legal services.
We do not guarantee the accuracy of information provided. Obligations may apply depending on your designated services. Always confirm your specific requirements with a qualified adviser.
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