Item 9 applies when a business provides a registered-office or principal-place-of-business address for a body corporate or legal arrangement in the course of carrying on a business. No fee or formal contract is required, but occasional mail handling or a purely private favour is not automatically captured. Record why the address is provided, how it supports the business and which entity or arrangement uses it.
Why an address is regulated
A registered office is where regulators, courts and creditors can contact an entity. Providing that address in the course of carrying on a business can therefore be a designated service without any client-money activity. The statutory business-course requirement still matters: establish the address use, customer and commercial context rather than treating every shared address or piece of forwarded mail as item 9.
Before you host an entity
- Verify the instructing client and the entity's beneficial owners before the address service starts
- Screen the client, controllers and beneficial owners against sanctions, PEP and adverse-media lists
- Record why the entity needs your address: the rationale should make commercial sense
- Rate the risk: offshore controllers, formations with no operating substance and rapid entity turnover all raise it
Ongoing discipline for hosted entities
The uncomfortable question your file must answer: if an examiner asked who operates from your address, could you show verified identity for every entity: today, not at formation time two years ago?
- Keep a register of every entity using your address, with review dates
- Handle official mail under a written protocol: logged, forwarded promptly, never opened beyond need
- Re-verify and re-screen on a risk-based cycle and when controllers change
- Review when ASIC or court documents arrive for an entity you barely know: that is a signal, not admin
- End the service formally when the relationship ends, and record the entity's new address where known
Red flags in address services
- Entities with no staff, premises or activity whose only Australian presence is your address
- Rapid cycles of companies registering at your address and going quiet
- Clients who resist identifying the people behind a hosted entity
- Official correspondence suggesting regulatory, court or liquidation action for entities you host
Official sources
Confirm the current rules against these primary sources.
Questions
We let a few long-term clients use our office as their registered address informally. Are we captured?
Possibly. A fee or formal contract is not required, but item 9 applies only where the address is provided in the course of carrying on a business for use as a registered office or principal place of business. Occasional mail handling or a purely private favour is not automatically captured. Record the business context and apply the exact test.
Does hosting an SMSF's corporate trustee at our address count?
The trustee's purpose does not decide scope. Item 9 applies if the relevant address is provided to the body corporate or legal arrangement in the course of carrying on a business. If that test is met, identify the customer and apply the program and CDD requirements to the service.
What records must we keep for address services?
Seven years: the verification and screening evidence for the client and its beneficial owners, the service arrangement, review decisions and any reports made to AUSTRAC.
General information for Australian professionals, not legal advice. It does not replace the AML/CTF Act, the Rules or AUSTRAC guidance. See our editorial standards.
Keep reading
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How BAS practices scope company and trust creation, legal-form restructuring, nominee arrangements and registered-office or principal-address services.
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