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How are umbrella/holding companies with multiple trading entities handled?

Each trading entity providing designated services is set up separately because each is a distinct legal entity with its own ABN, AML obligations and AUSTRAC position.

Each trading entity providing designated services is set up separately in easyAML. This is structurally different from multi-trading-name (same-ABN) setups - here, each child entity is a distinct legal entity with its own ABN, its own AML obligations, and its own AUSTRAC position.

Key principles:

  • Each designated-service-providing entity needs its own AML/CTF Program because each is a separate reporting entity under AUSTRAC's framework.
  • The umbrella / holding company only needs AUSTRAC enrolment if it itself provides designated services - holding companies that are pure parent entities (no operational service provision) don't have AML obligations of their own.
  • Users with cross-entity access can swap between entities via the platform's entity switcher, useful for compliance officers or principals overseeing multiple operational entities.
  • Subscription coverage: one Professional subscription covers 2 entities - so a firm with 2 trading subsidiaries can cover both under a single Professional plan. Beyond 2 entities, additional entity slots are typically priced per the agreement.

Common umbrella patterns:

  • Two-entity firm: Holding Co → Operating Co. Operating Co is the reporting entity; Holding Co isn't. One Professional subscription suffices.
  • Multi-entity group: Holding Co → multiple operating subsidiaries (e.g. accounting arm, trust services arm, business advisory arm). Each operating subsidiary is its own reporting entity; subscription needs to cover all of them.
  • Reporting Group: where the operational subsidiaries report through the lead entity for AML purposes - a specific AUSTRAC-recognised structure. See Section 6 and the Reporting Group case study in the appendix for detail.

For firms with complex group structures, the customer success team can scope the right subscription and configuration approach during onboarding.

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