Do trust and company service providers need to comply with Australian sanctions law + screening (DFAT)?
A computed answer from the Rules Mate applicability engine, with the exact condition, the outcome for every structure and size, and the primary source.
Short answer: Yes
Yes. This obligation applies to trust and company service providers whatever their structure or size. The deciding fact: Tranche 2 industry (Trust & company service providers) — AML/CTF reporting entity from 1 July 2026.
The obligation in brief
Comply with Australian sanctions law + screening (DFAT). Autonomous Sanctions Act 2011 + Charter of the United Nations Act 1945 + their regulations prohibit dealings with designated persons + entities. DFAT Consolidated List maintained.
Trigger: Dealings + transactions.
Why trust & company service providers get a different answer
Rules Mate runs its applicability engine across 9 business structures and 6 size bands for each of the 35 industries it maps. For 27 of those industries the answer for "Comply with Australian sanctions law + screening (DFAT)" is no. Trust & company service providers is one of the 8 where the answer is different: yes.
The deciding fact for trust and company service providers: Tranche 2 industry (Trust & company service providers) — AML/CTF reporting entity from 1 July 2026.
About the industry: Entities providing trust or company formation, registered agent, or nominee services. Tranche 2 captured.
Compare a professional services (general) business with 6–19 employees structured as a Pty Ltd company: the obligation does not apply (Requires an AML/CTF designated service or international activity or crypto / DCE activity).
Answer by business structure and size
Each cell is the engine's outcome for a business in trust & company service providers with that structure and size, assuming it sells to consumers and small businesses and holds customer contact details. "Check" means the obligation turns on a fact the industry does not settle.
| Structure | No employees | 1–5 employees | 6–19 employees | 20–99 employees | 100–499 employees | 500+ employees |
|---|---|---|---|---|---|---|
| Sole trader | Yes | Yes | Yes | Yes | Yes | Yes |
| Partnership | Yes | Yes | Yes | Yes | Yes | Yes |
| Trust | Yes | Yes | Yes | Yes | Yes | Yes |
| Pty Ltd company | Yes | Yes | Yes | Yes | Yes | Yes |
| Public company | Yes | Yes | Yes | Yes | Yes | Yes |
| Not-for-profit (unregistered) | Yes | Yes | Yes | Yes | Yes | Yes |
| Registered charity | Yes | Yes | Yes | Yes | Yes | Yes |
| Super fund | Yes | Yes | Yes | Yes | Yes | Yes |
| Foreign company | Yes | Yes | Yes | Yes | Yes | Yes |
What the obligation requires
- When due
- Continuous screening.
- Evidence to keep
- Sanctions screening tool integration; DFAT Consolidated List checks; risk assessment.
- Maximum penalty
- Criminal — up to 10 years imprisonment + corporate penalties
- Regulator
- See source
- Jurisdiction
- Commonwealth (national)
Other obligations where trust & company service providers differ from the norm
- Customer due diligence (KYC) on every customer: Yes
- Designate an AML/CTF Compliance Officer: Yes
- Detect + enhance due diligence on Domestic + Foreign PEPs: Yes
- Enrol with AUSTRAC as a reporting entity: Yes
- Maintain a written AML/CTF program: Yes
- Notifiable Data Breach (NDB) scheme: Yes
- All 15 answers for trust & company service providers
Other industries with a non-default answer
Questions
- Do trust and company service providers need to comply with Australian sanctions law + screening (DFAT)?
- Yes. This obligation applies to trust and company service providers whatever their structure or size. The deciding fact: Tranche 2 industry (Trust & company service providers) — AML/CTF reporting entity from 1 July 2026.
- Is the answer the same for every industry?
- No. For 27 of the 35 industries Rules Mate maps, the answer is no. Trust & company service providers is one of 8 industries with a different answer.
Related
Sources
Computed by the Rules Mate applicability engine from the published obligation corpus; facts last checked 3 October 2026. Rules Mate is not a law firm and this is general information, not legal advice. Confirm your position with the regulator source or a qualified adviser before acting.