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Are shelf company sales a designated service?

Yes, selling or transferring a shelf company in the course of business is a designated service under Item 5 of Table 6 from 1 July 2026.

Yes. Selling or transferring a shelf company in the course of business is a designated service under Item 5 of Table 6 of the AML/CTF Act, taking effect from 1 July 2026. A shelf company is one that has legal existence but has not engaged in business activity, and AUSTRAC treats them as one of the most common legal arrangements used to conceal the true ownership of assets.

The mechanics are clear-cut:

  • The relevant customer is the buyer or transferee of the shelf company.
  • The seller must conduct CDD on the buyer before the transfer.
  • The CDD obligation applies regardless of who the buyer is. If the seller transfers a shelf company to an accountant in the course of business, CDD is performed on the accountant. If the seller transfers to a natural person, CDD is performed on that natural person.

Two practical implications for shelf company providers:

  • The seller cannot rely on assumptions about the end-use of the shelf company. Even where the immediate buyer is a professional intermediary (e.g. an accountant acquiring the shelf company to on-sell or use for their own client), the CDD obligation sits at the point of transfer to that intermediary.
  • A separate AML/CTF obligation may arise downstream if the shelf company is later restructured or onward-transferred. That's a question for whichever party assists with the restructure (see the next entry on company incorporation services).

See AUSTRAC's Professional designated services page.

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