ARCaml for TCSPs: Compliance Made Simple
If you set up companies or trusts, Tranche 2 is about to become part of your daily workflow. Starting July 2026, you'll need to:
TCSPs: Creating Structures That Can Be Exploited
From 1 July 2026, Trust & Company Service Providers have AML/CTF obligations. AUSTRAC identifies that criminals use business structures and trusts to hide beneficial ownership and create distance between themselves and criminal proceeds.
TCSP Designated Services
- • Creating, restructuring or forming body corporates or legal arrangements
- • Acting as director, secretary or trustee
- • Acting as nominee shareholder
- • Providing registered office or business address
- • Managing money, securities or property
- • Selling shelf companies
- • Assisting corporate transactions
Why TCSPs Are Targeted by Criminals
- • Create corporate veils to obscure ownership
- • Establish layered trust structures
- • Provide nominee directors/shareholders
- • Give appearance of legitimacy
- • Enable cross-border structuring
You may not know you're helping criminals-which is why these obligations exist.
Client Behaviour Red Flags
- • Avoids face-to-face meetings
- • Doesn't understand their own business
- • Ends relationship when asked for info
- • Unusual knowledge of AML/CTF rules
- • Pays higher fees without clear reason
Complex Structure Red Flags
- • Requests to hide beneficial ownership
- • Large volumes of company creation
- • Shell/shelf company usage
- • Transfers with no apparent purpose
- • Multiple layers of holding companies
Foreign Jurisdiction Red Flags
- • Structures in tax haven jurisdictions
- • Foreign PEPs or associates
- • No local business presence
- • Complex cross-border arrangements
- • Sanctioned country connections
Key Dates for TCSPs
- 31 March 2026: AUSTRAC enrolment opens
- 1 July 2026: AML/CTF obligations commence
- 29 July 2026: Enrolment deadline (within 28 days of first designated service)
How ARCaml Solves Your Compliance Challenge
ARCaml is a CDD as a Service platform that handles your customer due diligence for complex corporate and trust structures.
Identity Verification
Automated KYC for directors, shareholders, trustees, and beneficial owners
Beneficial Ownership
Unwrap complex structures to identify ultimate beneficial owners
Source of Funds
Verify funding for company formation, trust settlements, and capital
PEP & Sanctions
Screen all parties against global PEP, sanctions, and adverse media