--- title: "Nominee Director AML/CTF Program Free | HeadStart Docs" description: "AML/CTF compliance program for nominee director service providers. TCSP obligations, client verification, SMR procedures. Ready for July 2026 Tranche 2." lang: en-AU json-ld: | [ { "@context": "https://schema.org", "@type": "Organization", "name": "HeadStart Docs", "legalName": "HeadStart Docs Pty Ltd", "url": "https://www.headstartdocs.com.au", "logo": { "@type": "ImageObject", "url": "https://www.headstartdocs.com.au/logo-512.png?v=4", "width": 512, "height": 512 }, "description": "AML/CTF compliance digital products and programs for Australian businesses under Tranche 2 regulations. Free program documents and AML Portal. 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We provide digital products for AML/CTF compliance, not legal services." } }, { "@context": "https://schema.org", "@type": "BreadcrumbList", "itemListElement": [ { "@type": "ListItem", "position": 1, "name": "Home", "item": "https://www.headstartdocs.com.au/" }, { "@type": "ListItem", "position": 2, "name": "Shop", "item": "https://www.headstartdocs.com.au/shop" }, { "@type": "ListItem", "position": 3, "name": "Tranche 2 Hub", "item": "https://www.headstartdocs.com.au/tranche-2" }, { "@type": "ListItem", "position": 4, "name": "Sanctions Search", "item": "https://www.headstartdocs.com.au/sanctions-search" } ] }, { "@context": "https://schema.org", "@type": "FAQPage", "mainEntity": [ { "@type": "Question", "name": "Do I still need a solicitor for AML/CTF Tranche 2 compliance?", "acceptedAnswer": { "@type": "Answer", "text": "Yes. HeadStart Docs products are digital publications that give you a substantial head start, but they must be reviewed and tailored by a qualified solicitor to your specific business circumstances before implementation." } }, { "@type": "Question", "name": "How is HeadStart Docs different from the free AUSTRAC Starter Kits?", "acceptedAnswer": { "@type": "Answer", "text": "AUSTRAC Starter Kits are generic starting points that require significant customisation. HeadStart products are sector-specific, pre-populated with industry-relevant risk factors and scenarios, and include 12 months of AML Portal access for ongoing compliance including screening, record keeping and reporting tools." } }, { "@type": "Question", "name": "What if the AML/CTF rules change after I purchase?", "acceptedAnswer": { "@type": "Answer", "text": "Your digital products are yours to keep. If significant regulatory changes occur, updated versions will be available to active portal subscribers. The AML Portal itself is continuously updated to reflect current AUSTRAC requirements and sanctions lists." } }, { "@type": "Question", "name": "What happens after my 12-month AML portal access expires?", "acceptedAnswer": { "@type": "Answer", "text": "Your documentation is yours forever. To continue using the AML Portal (screening tools, compliance calendar, record keeping), you pay $35 per customer CDD. Cancel anytime — no subscription required." } }, { "@type": "Question", "name": "Is HeadStart Docs a law firm?", "acceptedAnswer": { "@type": "Answer", "text": "No. HeadStart Docs is a digital publisher and platform provider. We sell digital compliance products and portal access. We do not provide legal advice. Referrals for legal advice can be made to our related law firm, HeadStart Counsel." } }, { "@type": "Question", "name": "When does AML/CTF Tranche 2 commence in Australia?", "acceptedAnswer": { "@type": "Answer", "text": "Tranche 2 AML/CTF obligations commence on 1 July 2026. All reporting entities in designated sectors including lawyers, accountants, real estate agents, conveyancers, and trust and company service providers must have their AML/CTF programs in place by this date." } } ] }, { "@context": "https://schema.org", "@type": "Service", "serviceType": "AML/CTF Program - Nominee Directors", "provider": { "@type": "Organization", "name": "HeadStart Docs" }, "description": "AML/CTF compliance program for nominee director service providers in Australia. Includes directorship services, client verification and reporting obligations under Tranche 2.", "areaServed": { "@type": "Country", "name": "Australia" }, "audience": { "@type": "BusinessAudience", "name": "Nominee Directors" } }, { "@context": "https://schema.org", "@type": "Product", "name": "Nominee Director AML/CTF Program Pack", "description": "Sector-specific AML/CTF program documentation for nominee director service providers under Tranche 2 regulations. Includes policies, procedures, training register and implementation support documentation.", "image": "https://www.headstartdocs.com.au/images/headstart-og-image.png", "sku": "nominee-director-standard", "brand": { "@type": "Brand", "name": "HeadStart Docs" }, "category": "AML/CTF Compliance Programs", "offers": { "@type": "Offer", "price": "249", "priceCurrency": "AUD", "availability": "https://schema.org/InStock", "url": "https://www.headstartdocs.com.au/programs/nominee-director-aml-program", "priceValidUntil": "2027-07-01", "seller": { "@type": "Organization", "name": "HeadStart Docs" } } }, { "@context": "https://schema.org", "@type": "BreadcrumbList", "itemListElement": [ { "@type": "ListItem", "position": 1, "name": "Home", "item": "https://www.headstartdocs.com.au/" }, { "@type": "ListItem", "position": 2, "name": "Programs", "item": "https://www.headstartdocs.com.au/programs" }, { "@type": "ListItem", "position": 3, "name": "Nominee Director AML Program", "item": "https://www.headstartdocs.com.au/programs/nominee-director-aml-program" } ] }, { "@context": "https://schema.org", "@type": "FAQPage", "mainEntity": [ { "@type": "Question", "name": "Do nominee director service providers need an AML/CTF program?", "acceptedAnswer": { "@type": "Answer", "text": "Yes. Providing nominee director services is a designated service under the TCSP category in Tranche 2. Providers must have an AML/CTF program before 1 July 2026." } }, { "@type": "Question", "name": "What makes nominee director services a TCSP designated service?", "acceptedAnswer": { "@type": "Answer", "text": "Arranging for a person to act as a nominee director or secretary of a company is a trust and company service that triggers AML/CTF obligations under the Anti-Money Laundering Act." } }, { "@type": "Question", "name": "What due diligence must nominee director providers perform?", "acceptedAnswer": { "@type": "Answer", "text": "Providers must verify the identity of the person requesting the service, identify beneficial owners, assess ML/TF/PF risk and conduct ongoing customer due diligence." } }, { "@type": "Question", "name": "What are the key risks for nominee director services?", "acceptedAnswer": { "@type": "Answer", "text": "Key risks include shell company abuse, layering of corporate structures to obscure beneficial ownership and facilitating money laundering through nominee arrangements." } } ] }, { "@context": "https://schema.org", "@type": "HowTo", "name": "How to Prepare for AML/CTF Tranche 2 as a Nominee Director Provider", "description": "Step-by-step guide for nominee director service providers to prepare for AML/CTF Tranche 2 compliance.", "totalTime": "P180D", "step": [ { "@type": "HowToStep", "position": 1, "name": "Identify your designated services", "text": "Confirm that providing nominee director services triggers TCSP obligations under Tranche 2." }, { "@type": "HowToStep", "position": 2, "name": "Appoint an AML/CTF Compliance Officer", "text": "Designate a senior person to oversee AML/CTF compliance and be the AUSTRAC contact." }, { "@type": "HowToStep", "position": 3, "name": "Conduct a risk assessment", "text": "Assess exposure to ML/TF/PF risks specific to nominee directorship arrangements." }, { "@type": "HowToStep", "position": 4, "name": "Develop your AML/CTF program", "text": "Create policies and procedures tailored to nominee director service operations." }, { "@type": "HowToStep", "position": 5, "name": "Establish customer due diligence procedures", "text": "Implement client identification, verification and beneficial ownership procedures." }, { "@type": "HowToStep", "position": 6, "name": "Set up transaction monitoring", "text": "Monitor for suspicious patterns in nominee arrangements." }, { "@type": "HowToStep", "position": 7, "name": "Train staff", "text": "Train staff on AML/CTF obligations, suspicious matter identification and reporting." }, { "@type": "HowToStep", "position": 8, "name": "Enrol with AUSTRAC", "text": "Register as a reporting entity before July 2026." }, { "@type": "HowToStep", "position": 9, "name": "Set up recordkeeping", "text": "Establish systems to retain AML/CTF records for required periods." }, { "@type": "HowToStep", "position": 10, "name": "Schedule regular reviews", "text": "Plan annual reviews of your AML/CTF program and risk assessment." } ], "author": { "@type": "Organization", "name": "HeadStart Docs" } }, { "@context": "https://schema.org", "@type": "BreadcrumbList", "itemListElement": [ { "@type": "ListItem", "position": 1, "name": "Home", "item": "https://www.headstartdocs.com.au/" }, { "@type": "ListItem", "position": 2, "name": "Programs", "item": "https://www.headstartdocs.com.au/programs" }, { "@type": "ListItem", "position": 3, "name": "Nominee Director AML Program", "item": "https://www.headstartdocs.com.au/programs/nominee-director-aml-program" } ] } ] --- [Get Started ](/checkout) We use cookies to enhance your experience and analyse traffic. [Privacy Policy](/privacy) Essential OnlyAccept All [Skip to main content](#main-content) [ ![HeadStart Docs](/assets/logo-dark-bg-CUivuKJ8.png)![HeadStart Docs](/assets/logo-light-bg-D5BRMGqf.png) ](/) [Home ](/) Features [Programs ](/programs) Resources Sectors [Log in ](/auth) [Portal](/aml-landing) 1. [](/) - [Programs](/programs) - Nominee Director AML Program Nominee Director Sector # AML/CTF Program ## Nominee Director Sector Edition Nominee director service providers are squarely in scope as TCSPs under Tranche 2. This pack includes sector-specific policies, a risk assessment and a configuration schedule. Complete the schedule manually or with our Plug & Play Technology and your portal configures to match. Your lawyer reviews and signs off. You could be set up within a day. 12 sector-specific compliance documents Pack-exclusive portal features unlocked Configuration schedule drives your portal Instant download Tranche 2 Compliance [Learn About AML for Nominee Directors](/tcsp/nominee-directors) Standard Sole traders, single-director companies and multi-staff businesses $249 Group Multiple entities under one group $1,500 $249 +GST · One-time · Instant access Consultant-prepared AML programs typically cost $8,000 or more. Your professional starting point is $249 — or sign up and bring your own program. Everything below is sector-specific and pre-populated for your practice. - Complete AML/CTF program documentation (12 documents, pre-populated for your sector) - Customisable services gateways and decision trees to implement any guardrails and for staff to check what is and is not a designated service - Shared CDD with e-signature: send verification requests directly to clients - Automated annual reporting: AUSTRAC reporting workflows built in - Smart Extract: AI-assisted form filling across your compliance documents - 20 portal seats included - CDD at $35/customer, pay-as-you-go The portal isn't separate from your program. It's where your program lives and operates. Your configuration schedule drives how the portal works: your CDD workflows, your screening thresholds, your compliance calendar, your reporting obligations - all pre-set to match your actual business. Get Started Secure checkout · Instant digital delivery See sample pages ## Risk Intelligence for Nominee Director Providers Every sector faces different money laundering risks. These are the scenarios AUSTRAC will expect your program to address. They're already mapped into your pack. Covered in Pack ### Identity Verification Customer due diligence Inadequate verification of customer identity leading to onboarding of high-risk clients. Covered in Pack ### Unusual Transactions Transaction monitoring Failure to detect structured payments or unusual transaction patterns. Covered in Pack ### Sanctions Exposure Prohibited dealings Risk of inadvertently dealing with sanctioned entities or persons. Covered in Pack ### Beneficial Ownership Ownership opacity Complex ownership structures obscuring the true beneficial owners of assets or entities. ## How it works One configuration schedule drives your entire AML program and portal setup. 1 ### Download your pack Pre-drafted policies, risk assessment and configuration schedule, all sector-specific. 2 ### Complete the configuration schedule Your business details, designated services, risk thresholds and client onboarding process. Fill it in manually or use our Plug & Play Technology to complete it in minutes. [Learn more about Plug & Play →](/plug-and-play) 3 ### Your portal auto-configures Your lawyer reviews the completed pack and configuration schedule before you go live. Your CDD workflows, screening thresholds, compliance calendar and reporting obligations are all pre-set to match your actual business. You could be set up within a day. General information only. Not legal advice. Always take advice specific to your circumstances. ## What's Included Every free account includes sector-specific compliance documentation and full AML Portal access. Download, review with your lawyer and have your program ready before 1 July 2026. Compliance Documents ### Risk Assessment ML/TF Risk Assessment and Customer Risk Assessment Matrix tailored to your sector. ### AML/CTF Program Your core AML/CTF program document with policies, procedures and controls tailored to your designated services. ### CDD Procedures Customer due diligence procedures, Client Information Sheet and Decision Trees. ### Governance Board Minutes, AML Officer Appointment and Employee Due Diligence documents. ### Training and Compliance Staff Training Register and Compliance Calendar for ongoing obligations. ### Implementation Implementation Plan, Enrolment Guide and Briefing Note to get started. AML Portal Access ### Sanctions and PEP Screening Sanctions screening, PEP checks and adverse media monitoring in one place. ### Compliance Calendar Track deadlines and recurring compliance tasks with automated reminders. ### CDD Record Keeping Centralised record keeping with immutable audit log for every action. ### Plug & Play Technology Complete one configuration schedule and your portal configures automatically. Takes minutes, not days. [Learn more →](/plug-and-play) ### Transaction Reporting Built-in tools for threshold and suspicious matter reporting workflows. ### Training Records Personnel training record-keeping with completion tracking and reminders. 20 seats included with Standard edition. 100 seats with Group edition. CDD is $35 inc GST per customer. ## Who May Be Captured Tranche 2 is broader than most people expect. If any of the following describes your practice, you're a reporting entity and you need an AML program before 1 July 2026. Nominee director providers Acting as director on behalf of others Fiduciary service providers Trustee and fiduciary arrangements Corporate governance firms Providing officeholder services Whether you are captured depends on the designated services you provide. If unsure whether you're covered, please seek legal advice. Even if you are not covered, you may consider implementing guardrails to ensure you don't accidentally cross lines. ### Built Upon National and International Standards [NRA: Money Laundering (2024) ](https://www.austrac.gov.au/business/how-comply-guidance-and-resources/guidance-resources/money-laundering-australia-national-risk-assessment-2024)• [NRA: Terrorism Financing (2024) ](https://www.austrac.gov.au/business/how-comply-guidance-and-resources/guidance-resources/terrorism-financing-australia-national-risk-assessment-2024)• [NRA: Proliferation Financing (2022) ](https://www.austrac.gov.au/business/how-comply-guidance-and-resources/guidance-resources/proliferation-financing-australia-national-risk-assessment-2022)• [FATF NRA Guidance (2025) ](https://www.fatf-gafi.org/en/publications/Methodsandtrends/Money-Laundering-National-Risk-Assessment-Guidance.html) ## Need more context before you start? Not sure if your practice is captured? Read our free Nominee Director Sector guide first. It covers exactly which services trigger your obligations and what AUSTRAC will expect to see. [Back to Sector Education](/tcsp/nominee-directors) ## What happens after I sign up? Three simple steps from sign-up to compliance. 1 ### Download immediately Your complete sector-specific program documents are available in your portal immediately. No waiting, no onboarding. 2 ### Complete your configuration schedule Fill it in manually or use our Plug & Play Technology to complete it in minutes. This single document sets up your portal and forms part of your compliance documentation. Your lawyer reviews the completed schedule and program before you go live. [See how it works →](/plug-and-play) 3 ### Go live before 1 July 2026 Use the AML Portal to run your compliance program digitally, or take the documents to your own systems. Either way, you get a complete starting point ready for your lawyer to review. Your obligations are ongoing and the portal is built to help you manage them. 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HeadStart Docs™ is a digital publisher and platform provider. We sell digital compliance products including publications and portal access to our AML Portal; we do not provide legal advice or services. The content on this website and in our products is for general information purposes only, does not consider your individual and business circumstances, and should not be relied on as legal advice. Referrals for legal advice can be made, on request, to HeadStart Counsel, the registered trading name of Astris Law Pty Ltd, a related incorporated legal practice with the same director and beneficial owner as HeadStart Docs. You are free to engage any legal practitioner of your choice.