Designated services · 5 of 13 · Table 6, item 9

Lending a client your address, and where AML/CTF touches it

Hundreds of firms let a client’s company use the office address, often without charging for it. Since 1 July 2026 that is a designated service, and the fee makes no difference.

All thirteen designated services

Start here

What this service is

One address, several companies

Every Australian company must give ASIC a registered office address. It goes on the public record, and it is where official documents get sent.

Plenty of companies have no address of their own. A holding company, a corporate trustee, a dormant entity — none of them has a front door. So the accountant or the lawyer says: use ours.

That is item 9. Providing the registered office address, or the principal place of business address, of somebody else’s company. It is usually a tick on a form, it is often free, and it is now a designated service.

Why this happens at all

How firms end up holding a client’s address

	Why
Every company must have one	The Corporations Act requires a registered office address, on the public record
Documents are served there	ASIC and anybody suing the company send documents to that address
Many companies have no premises	A holding company or a trustee company may have no office of its own
So the adviser lends theirs	The accountant’s or lawyer’s address goes on the ASIC record instead

The size of it

3.72 million addresses on the public record

Nobody publishes how many of those belong to the company’s adviser rather than the company. But any firm that registers companies for clients will have a list, and the honest way to find it is to search the ASIC register for your own street address.

Companies on the register

3.72m

Every one has a registered office address on the public ASIC record

Price that makes it caught

Providing the address free of charge is still a designated service

Address type required

Street

A PO box or mailing address is not a registered office

Captured since

1 Jul 2026

Address services became a designated service under Table 6, item 9

The part most firms miss

Charging nothing does not make it nothing

AUSTRAC’s guidance is explicit: providing the address free of charge is still providing the service. There is no minimum fee and no exemption for a courtesy.

That is why this one gets missed. A designated service you bill for shows up in your fee schedule when you sit down to work out what you provide. A favour you did for a client in 2019 shows up nowhere — except on the ASIC record, where it has been sitting ever since.

It is also a continuing service rather than a one-off. The obligation does not end when the company is registered; it runs for as long as your address stays on the record.

A practical first step: search the ASIC register for your own address and see how many companies come back. That list is your starting population.

Are you providing it?

A street address supplied instead of theirs

Address arrangements, sorted

The arrangement	Caught?
Your firm’s address is the registered office of a client’s company	Caught
You offer a registered business address as part of an ASIC registration	Caught
You make your address available for a company about to be incorporated	Caught — the service starts when the address is made available, not when ASIC records it
You do any of the above and never send a bill	Caught — charging nothing changes nothing
You give a client a mailing address or PO box	Not caught — a registered office must be a physical street address
You lease premises to a company that actually operates from them	Not caught — that is where it operates, not an address supplied instead of one

The PO box line matters because it is the one clean exclusion. A registered office has to be a physical street address where documents can be served, so a mail forwarding service is not item 9. The landlord line matters for the opposite reason: if a company genuinely operates from premises you lease to it, that is its own address, not one you supplied in place of one.

What actually gets checked

Six checks, and one of them is the point

Looking through the entity is the check that earns its keep here. The reason this service is in the Act at all is that a company with no premises, no staff and an adviser’s address is a convenient shell. Knowing who actually owns it is the whole exercise.

The loop on the left is the point. This obligation does not end when the address is lodged — it runs for every year your address stays on that record.

The checks, how they are done, and what you keep

The check	What is required	How it is usually done	What stays in the file
Identify the customer	Full name, date of birth and residential address of the person the service is provided to	Licence or passport, in person or by digital check	What was collected and how it was verified
Look through the entity	Beneficial owners of the company using your address — generally 25% or more	ASIC extract, share register, trust deed	Who they are and the document relied on
Screen for PEPs and sanctions	Whether the customer is politically exposed, and a check against the DFAT Consolidated List	A screening tool, or a manual DFAT search	The result and its date
Understand the purpose	Why this company needs your address rather than one of its own	Usually obvious for a dormant holding company; less so otherwise	A note where the reason is not obvious
Rate the risk	Assess and record the ML/TF risk	Your program’s risk factors — a company with no premises and offshore owners is not the same as a client’s family trustee	The rating and the reasons
Keep watching	Monitor for as long as the arrangement lasts	These run for years quietly — review when ownership or officeholders change	What you reviewed, when, and what you concluded

Records are kept for 7 years. This is a continuing service, so the monitoring obligation runs for the life of the arrangement.

The provision itself

Table 6, item 9, in the Act’s own words

THE ACT — s 6(5B) TABLE 6, ITEM 9

“providing a registered office address or principal place of business address of a body corporate or legal arrangement, in the course of carrying on a business”

Customer: the person to whom the service is provided. Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth), s 6(5B) table 6, item 9 — Compilation No. 62 (C2026C00274).

Notice what the wording does not say. There is no fee, no threshold and no minimum duration. The only condition is that you do it in the course of carrying on a business. If you are registering companies as well, you are likely providing two designated services on the same engagement.

The thirteen designated services

One article for each service you can select when you enrol

13 of 13 written so far. The rest are in progress.

Professional services

Conveyancing
Every step of a settlement, and how CDD differs from the VOI you already do.
Table 6, item 1
Selling a business
When a company or trust changes hands.
Table 6, item 2
Client money
Holding or controlling someone else’s money or property in a transaction.
Table 6, item 3
Equity and debt financing
Raising money for a company or legal arrangement.
Table 6, item 4
Shelf companies
Selling or transferring a company created to be sold.
Table 6, item 5
Company and trust formation
Creating or restructuring a company, trust or partnership.
Table 6, item 6
Director and trustee roles
Acting as, or finding someone to act as, a director, trustee or attorney.
Table 6, item 7
Nominee shareholders
Holding shares in your name for somebody else.
Table 6, item 8
Registered officeyou are here
Letting a client use your address as their registered office.
Table 6, item 9

Real estate

Real estate agents
The agent’s customer is both sides of the deal — and the two sides start at different moments.
Table 5, item 1
Property developers
Selling your own stock with no agent in between, and why that changes who the customer is.
Table 5, item 2

Bullion and precious goods

Bullion
Gold, silver, platinum and palladium, and the $5,000 exemption.
Table 2, item 1
Jewellers and dealers
Why the $10,000 line is about how the customer pays, not what they buy.
Table 2, item 2

Sources

Where every figure here comes from

Data as at 27 September 2026.

Anti-Money Laundering and Counter-Terrorism Financing Act 2006, s 6(5B) table 6 · Federal Register of Legislation · Compilation No. 62 (C2026C00274)
Item 9 and its customer definition, quoted verbatim on this page.
Professional designated services · AUSTRAC · Guidance, current at Sep 2026
That the service is caught when provided free of charge, and that the street-address requirement excludes PO boxes.
Registered office and principal place of business · ASIC · Current guidance
What a registered office is and what the Corporations Act requires of it.
Company registration statistics · ASIC · Published monthly
Companies on the register.

Before you rely on this

This content is general information only. It is not legal, financial or compliance advice. Organisations should check AUSTRAC guidance, legislation, their own AML/CTF Program and professional advice where needed.

Whether a particular address arrangement is a designated service depends on its own facts, including whether it is provided in the course of carrying on a business.
Searching the ASIC register for your own address is a practical starting point, not a legal test. Some results may be companies that genuinely operate from your building.
Figures are as at 27 September 2026 and come from the sources listed above.

Lex-AML supports compliance workflows and record keeping. It does not provide legal advice, does not guarantee compliance, and does not replace professional judgement or advice from a qualified AML/CTF adviser or legal professional.

Why a technology company writes this

GetPost Labs is a technology company. We are not a law firm and not a compliance adviser, and this page is not a substitute for either.

We build Lex-AML. To build it properly we had to understand these obligations the way the people carrying them do, so we researched them with small and medium practices across the affected sectors — how the work actually runs, where the law lands inside it, and which questions were hardest to get a straight answer to. Publishing what we found is how we check that we have understood a requirement before we build for it.

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So this is an offer of capability, not a pitch. If Lex-AML turns out to fit your practice, we would like to work on it with you. If it does not, what is written on this page stands on its own, and every source it rests on is listed above so you can check it yourself.