Tranche 2
Providing a registered office or business address: AML/CTF obligations for TCSPs and accountants
Offering your address as a client's registered office looks like a small administrative courtesy. Under Tranche 2 it is a designated service — because an address you control can anchor a structure nobody can knock on. Practices that host client entities carry real, ongoing obligations for every one of them.
Why an address is regulated
The registered office is where regulators, courts and creditors go to find an entity. When a practice provides that address as a service, the practice becomes part of the entity's visibility chain. The AML/CTF Act therefore treats providing a registered office or principal place of business for a client as a designated service in its own right — no money handling required.
Before you host an entity
- Verify the instructing client and the entity's beneficial owners before the address service starts
- Screen the client, controllers and beneficial owners against sanctions, PEP and adverse-media lists
- Record why the entity needs your address — the rationale should make commercial sense
- Rate the risk: offshore controllers, formations with no operating substance and rapid entity turnover all raise it
Ongoing discipline for hosted entities
The uncomfortable question your file must answer: if an examiner asked who operates from your address, could you show verified identity for every entity — today, not at formation time two years ago?
- Keep a register of every entity using your address, with review dates
- Handle official mail under a written protocol: logged, forwarded promptly, never opened beyond need
- Re-verify and re-screen on a risk-based cycle and when controllers change
- Review when ASIC or court documents arrive for an entity you barely know — that is a signal, not admin
- End the service formally when the relationship ends, and record the entity's new address where known
Red flags in address services
- Entities with no staff, premises or activity whose only Australian presence is your address
- Rapid cycles of companies registering at your address and going quiet
- Clients who resist identifying the people behind a hosted entity
- Official correspondence suggesting regulatory, court or liquidation action for entities you host
Frequently asked questions
We let a few long-term clients use our office as their registered address informally. Are we captured?
Yes — formality is irrelevant. Providing the address as a service is a designated service whether it is invoiced or a favour. Bring those arrangements into your program: verify the controllers, record the arrangement and set review dates.
Does hosting an SMSF's corporate trustee at our address count?
Providing the registered office is the designated service, whatever the entity's purpose. The client type changes the risk assessment, not the capture.
What records must we keep for address services?
Seven years: the verification and screening evidence for the client and its beneficial owners, the service arrangement, review decisions and any reports made to AUSTRAC.
Put it into practice
Cassandra AML turns these obligations into a working system: designated-service decisions, customer due diligence, screening, monitoring and reporting records — hosted in Sydney, free to start.
This guide is general information for Australian professionals. It is not legal advice and does not replace the AML/CTF Act, the AML/CTF Rules or AUSTRAC guidance. Confirm your specific obligations with AUSTRAC or a qualified legal adviser.