AML/CTF Compliance for Fund Managers & Trustees

AML Smart Guard provides AML/CTF compliance support for fund managers, trustees and trust and company service providers (TCSPs), including identity and beneficial ownership verification, risk assessment, transaction monitoring, training and specialist support.

What AUSTRAC expects from funds and trustees

AML/CTF obligations depend on the designated services a fund manager, trustee or TCSP provides. For trust and company service providers, this can include services such as creating or restructuring trusts or companies, acting or arranging for someone to act in certain positions, managing property in connection with transactions, or providing registered office services. Existing financial services businesses may also have AML/CTF obligations under other designated services.

Which plan is right for me?

Structure	Recommended plan	Why
Single family trust or TCSP providing designated services	Flex/Bespoke	Screening matched to occasional beneficiary changes
Managed fund with regular investor turnover	Standard or Scaled	Predictable monthly screening volume
Multi-entity TCSP or layered fund structure	Enterprise	Unlimited users, dedicated account manager for complex beneficial-ownership tracing

How does AML Smart Guard support reporting and record keeping?

AML Smart Guard centralises customer due diligence, risk assessments, monitoring activity and relevant compliance records, helping businesses maintain accessible records and information to support their AML/CTF reporting and oversight requirements.

Frequently asked questions

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What should a fund manager’s AML program focus on?

Risk-rate investors and structures at onboarding, apply enhanced due diligence to complex or layered vehicles, and monitor subscriptions, redemptions, and distributions on an ongoing basis.

What does enrollment and program build look like for a TCSP?

Confirm which trust and company services are in scope, appoint a compliance officer, complete AUSTRAC enrolment, and build the program around the specific structures administered.

Does this cover self-managed super funds (SMSFs)?

It depends on the services being provided. An SMSF isn’t automatically subject to Tranche 2 obligations simply because it’s an SMSF. Trustees and professional service providers should consider whether the services they provide fall within an AML/CTF designated service.