Your customer depends on the designated service you provide, not on who engages you. Work out the designated service first, then who the customer is, and complete initial customer due diligence (CDD) on that customer before you start providing the service.
Prepared with reference to AUSTRAC guidance current as at 10 November 2026. AML/CTF requirements are evolving, so seek legal or compliance advice if you're unsure what applies to your firm.
Contents
Who is the customer for each designated service?
Table 6 of the AML/CTF Act lists nine professional designated services. Each one names its customer.
| Item | Designated service | Customer |
|---|---|---|
| 1 | Assisting with a transaction to sell, buy or transfer real estate | The person you assist or act for |
| 2 | Assisting with a transaction to sell, buy or transfer a body corporate or legal arrangement | The person you assist or act for |
| 3 | Receiving, holding and controlling, or managing, a person's money or property as part of a transaction | The person |
| 4 | Assisting with equity or debt financing for a body corporate or legal arrangement | The person |
| 5 | Selling or transferring a shelf company | The buyer or transferee |
| 6 | Assisting with creating or restructuring a body corporate or legal arrangement | The person, plus (when creating a company) its beneficial owners and directors, or (when creating an express trust) its trustee, settlor and beneficiaries |
| 7 | Acting as, or arranging for someone to act as, a director, secretary, trustee, partner or similar | The nominator (the person you act on behalf of) |
| 8 | Acting as, or arranging for someone to act as, a nominee shareholder | The nominator |
| 9 | Providing a registered office address or principal place of business address | The person you provide the address to |
A legal arrangement includes an express trust, a partnership, a joint venture and an unincorporated association. For the detail of each service, see AUSTRAC's professional designated services guidance.
Registered office or principal place of business address
When you let a company use your address as its registered office, the company is the customer. Its directors aren't separate customers for this service. They're covered by the company's CDD (see What does CDD on a company or trust cover?).
You start providing this service when you make the address available, even if the company hasn't given it to ASIC yet. It only applies when the address is used in place of an address the entity operates its business from.
Creating a company or trust
When you help create a company or an express trust, your customers are wider than the person instructing you:
- Creating a company: the person instructing you, and the proposed beneficial owners and directors of the company.
- Creating an express trust (including a discretionary trust, unit trust or SMSF): the person instructing you, and the proposed trustee, settlor and beneficiaries.
Because the company or trust doesn't exist yet, CDD focuses on these people. The service also covers preparatory steps, such as drafting a constitution or trust deed, or lodging registration forms with ASIC.
Restructuring means changing the legal form of a company or arrangement, such as a merger or demerger. Changes to staffing, systems or other things unrelated to legal form aren't restructuring.
What does CDD on a company or trust cover?
CDD on a company or trust customer includes the people connected to it. You don't run a separate CDD on each of those people unless they're also your customer for a designated service.
Company
- The company's identity, such as its name and ACN, from ASIC.
- Each director's full name and director identification number (director ID).
- The beneficial owners: individuals who own 25% or more, or who control the company.
- Anyone acting on the company's behalf, and their authority to act.
- Whether the company, its beneficial owners or anyone acting for it is a politically exposed person (PEP) or designated for targeted financial sanctions.
Trust
- The trust's identity, such as its name and type.
- Each trustee. For a corporate trustee, identify the company and its beneficial owners.
- The trust's beneficial owners, including settlors, appointors, guardians, protectors and beneficiaries, as AUSTRAC's trust guide sets out.
- PEP and targeted financial sanctions screening for these people.
If you've verified the individuals behind a corporate trustee, you still need to identify the trustee company itself, for example with an ASIC search.
Self-managed super funds (SMSFs)
An SMSF is a trust, so the trust CDD requirements apply, as they do for a discretionary trust.
For the full list of information to collect and verify, see AUSTRAC's initial CDD guide for a body corporate and initial CDD guide for a trust. For an overview, see What is Customer Due Diligence (CDD)?.
What isn't a designated service?
- Tax returns and compliance work: preparing tax returns, BAS, financial statements and annual compliance aren't Table 6 designated services. If this is all you do for a client, you don't select a designated service for them.
- Testamentary trusts: these aren't express trusts, so drafting a will and creating a testamentary trust isn't a designated service under items 2 and 4 to 9.
- Transfers from a deceased estate following a court grant of probate or letters of administration are excluded from items 1 and 2.
- General advice that only influences a transaction, without directly advancing it.
Recording designated services in Firm Verify
Select the designated services on the client record of each customer you provide them to, not on their related parties. You select them in two places:
- The Services page of Client Onboarding, in Service to Provide.
- The Services profile in Step 1 of Initial Client Due Diligence.
The list of services comes from your firm's current risk assessment. The services you select feed the services risk factors in the client's risk assessment.
Add directors, trustees, beneficial owners and representatives as related parties in the client's CDD. They aren't charged as entities unless you also set them up as clients and run CDD on them. Any verification checks you run on them are charged per check. See Firm Verify Pricing and Billing.
Frequently asked questions
Select a question to see the answer.
We're the registered office for a company. Do we select that service for the company, its trust and its directors?
Select it for the company only, because the company is the customer. The directors are covered by the company's CDD. If you also provide your address to the trust as its principal place of business, select the service on the trust's record too.
If we provide registered office services, whose CDD is required: the director or the corporate trustee?
The corporate trustee company, as the entity using your address. Its directors and beneficial owners are identified as part of that CDD.
How do we verify a new company we're setting up?
Until it's registered, your customers are the person instructing you and the proposed directors and beneficial owners, so complete CDD on them. Once the company exists and you provide another designated service to it, such as a registered office, the company is the customer for that service. See Creating a company or trust.
Do we need to verify identity at both the individual level and the company level?
When the company is the customer, you identify the company and, within the same CDD, its beneficial owners and anyone acting for it. You don't need a separate CDD on each individual unless they're also your customer for a designated service.
If we do CDD on a company, do we need separate CDD on its related parties?
No. Related parties are covered within the client's CDD. In Firm Verify, add them in Step 4 of initial CDD. They aren't charged as entities unless you also add them as clients and run CDD on them.
Do we need to check the trustee company if we've already checked the individuals?
Yes. Identify the trustee company itself, for example with an ASIC search. Verifying the individuals who own or control it covers its beneficial owners, but not the company itself.
Are the requirements for a new SMSF client from another accountant the same as for a discretionary trust?
Yes. Both are trusts, so the trust CDD requirements apply. CDD is needed only if you'll provide a designated service to the fund. Annual accounts, tax returns and other compliance work aren't designated services.
Is compliance work or preparing tax returns for a company a designated service?
No. These aren't Table 6 services. Registered office, company secretarial appointments and restructures can be, so check everything else you do for the company.
Are estates and testamentary trusts exempt?
Testamentary trusts aren't express trusts, so they're outside items 2 and 4 to 9. Transfers of property or entities from a deceased estate following probate are excluded from items 1 and 2. Other services you provide to an estate can still be designated services.
How do designated services work when we just add an individual?
Adding a client is free and doesn't start CDD. An individual is your customer only if you provide them a designated service, for example instructing you to set up a trust, or nominating someone to act as a director. Select that service on their client record, then run initial CDD.
Related articles
For CDD obligations by customer type, see What is Customer Due Diligence (CDD)?. To run CDD in Firm Verify, see Initial Client Due Diligence.