AML Compliance Guide
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Sanctions screening for Trust and company service providerss — 2026 AUSTRAC Guide

If you provide trust and company services that are designated services from 1 July 2026, you must screen your customers against Australia’s sanctions lists before you act for them and keep screening during the relationship. This matters for trust and company service providers because you may be setting up companies, trusts or other structures, appointing officeholders, or handling instructions that could be used to move or conceal assets. If you provide a service to a sanctioned person or entity, that can be a strict-liability criminal offence, and broader AML/CTF contraventions can also expose your business to civil penalties of up to $33.5 million per contravention.

Your AML/CTF obligations

  1. 1. AUSTRAC enrolment
  2. 2. Compliance officer
  3. 3. ML/TF risk assessment
  4. 4. AML/CTF program
  5. 5. Customer due diligence
  6. 6. Sanctions screening
  7. 7. Suspicious matter reporting
  8. 8. Record keeping (7 years)
  9. 9. Staff training

Sanctions screening means checking whether the customer, beneficial owners, controllers, trustees, settlors, directors, officeholders, representatives and anyone you are dealing with for the structure appears on the DFAT autonomous sanctions list or the UN Security Council consolidated list. For a trust and company service provider, this is not just about the named client on the engagement letter. If you are forming a company, supplying a registered office, acting as nominee director, arranging a trust, or providing similar services, you need to understand who ultimately owns or controls the structure and screen those people as well.

What you should do in practice

  • Identify every relevant party before you provide the designated service: the customer, any beneficial owner holding 25% or more, anyone exercising effective control, trustees, directors, appointors, and authorised representatives.
  • Run sanctions checks before onboarding using the DFAT autonomous sanctions list and the UN Security Council consolidated list, and record the date, search terms, results and who performed the check.
  • Do not proceed if you get a potential match until you have escalated it internally and resolved whether it is a true match. For high-risk matters, involve your AML/CTF compliance officer before taking any step to form the entity or implement the arrangement.
  • Repeat screening during the relationship, especially when ownership changes, new directors or trustees are appointed, distributions or control rights change, or the client becomes connected to a higher-risk country.
  • Keep evidence of every check with your CDD records and AML/CTF records for 7 years after the relationship ends.

Do not treat this as a one-off check

For trust and company work, sanctions risk can change after onboarding. A clean result when a company is formed does not cover later changes to shareholders, controllers, trustees or beneficiaries. Ongoing screening is required before and during the relationship.

A common mistake in this sector is screening only the instructing individual and ignoring the people behind the structure. Another is assuming an Australian company or trust is automatically low risk. A local entity can still be controlled by an overseas sanctioned person through layered ownership, nominee arrangements or family connections. You also cannot rely on the fact that a matter looks administrative, such as changing a director or updating a share register. If that change gives control to a sanctioned person, providing the service creates real exposure.

Build sanctions screening into the same workflow you use for customer due diligence. When you collect ASIC details, trust deed information and beneficial ownership information, require sanctions checks before the file can move to engagement or implementation. For remote clients, complex family trusts, shelf companies, foreign controllers, or unusual requests involving rapid changes in ownership or control, treat the matter as higher risk and consider enhanced due diligence as well. Your staff should know that if a name resembles a listed person, they must escalate it and must not tell the client that a suspicious matter report has been or may be filed, because tipping off is a separate criminal offence.

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Frequently asked questions

Do I only screen the company or trust itself, or the people behind it as well?
You screen more than the entity name. For trust and company service work, you should screen the customer, beneficial owners, controllers, trustees, directors, appointors, representatives and others who ultimately own or control the structure. That is the only practical way to identify whether a sanctioned person is behind the arrangement.
If I am just setting up a shelf company or providing a registered office, do I still need to do sanctions screening?
Yes, if what you are providing is a designated service. Even where the work looks administrative, you are still helping create or maintain a legal structure that can hold assets or be used in transactions. You need to screen before providing the service and continue screening during the relationship.
What if a client is an Australian resident and the trust assets are all in Australia?
You still need to screen. Sanctions obligations are federal and apply regardless of which state or territory you operate in, and Australian residency does not rule out sanctions risk. A person can live in Australia and still be a listed person or be connected to a listed entity.
Do I have to pay for a screening platform?
The law requires screening, but it does not require a particular software product. A small practice may use a manual process if it is reliable, documented and repeated when needed, but many firms use software to reduce missed matches and keep records. Your process must suit the size of your practice and the complexity of the structures you handle.
What should I do if there is a possible match on a director or beneficial owner?
Pause the matter and escalate it under your AML/CTF procedures before you provide the service. Check whether it is a true match by reviewing identifiers such as full name, date of birth, country and role in the structure, and involve your AML/CTF compliance officer. Do not tell the client that you have filed or are considering filing a suspicious matter report.

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