A Trust or Company Service Provider (TCSP) licence is required to carry on a trust or company service business in Hong Kong. It is issued by the Companies Registry under the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (AMLO), and it applies to the corporate-services work that sits close to the flow of company ownership and control.
As with the MSO regime, the licence exists to bring these services inside the AML framework. The Registry assesses whether the provider and its officers are fit and proper and whether the firm runs proper customer due diligence on the companies and clients it serves.
What a TCSP licence covers
The licence is required where, by way of business, you provide trust or company services to others.
- Forming companies or other legal persons.
- Acting as, or arranging for another person to act as, a director or secretary of a company.
- Providing a registered office, business address or correspondence address.
- Acting as, or arranging for another person to act as, a trustee or a nominee shareholder.
Fit-and-proper and beneficial ownership
The Companies Registry assesses the applicant and its key personnel — directors, partners and ultimate owners — against a fit-and-proper standard. Because TCSP work touches company control and nominee arrangements, clear and verifiable beneficial ownership of the applicant itself is central to the assessment.
AML controls the Registry expects
A TCSP must run a customer-due-diligence and record-keeping programme on the clients and structures it services, screen against sanctions, monitor for suspicious activity, and report where required. A designated compliance officer owns the framework. The quality of that programme is a large part of what the Registry is licensing.
Application and term
The application is made to the Companies Registry with documentation on the business, its ownership and its AML framework. Once granted, a TCSP licence runs for a fixed term (up to three years) and is renewable, subject to continuing AML obligations and the Registry’s supervision.
What we do on tcsp licence application.
- Confirm whether your corporate-services business needs a TCSP licence.
- Prepare fit-and-proper and beneficial-ownership documentation for the applicant.
- Build the AML/CFT programme for the trust and company services you provide.
- Manage the Companies Registry application through to grant, and renewals after.
- Provide or run the ongoing compliance function as an outsourced service.
Frequently asked
Who issues the TCSP licence in Hong Kong?
The Companies Registry licenses and supervises Trust or Company Service Providers under the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (AMLO).
How long is a TCSP licence valid?
A TCSP licence is granted for a fixed term of up to three years and is renewable, with continuing anti-money-laundering obligations throughout.
Do company secretaries and formation agents need a TCSP licence?
If you provide trust or company services — company formation, registered office, acting as or arranging directors, secretaries, trustees or nominees — by way of business, a TCSP licence is generally required. RETU can confirm against your specific activities.
Can I hold both a TCSP and an MSO licence?
Yes — they cover different activities (corporate services versus money changing and remittance) and some groups hold both. Each has its own application and ongoing AML obligations.
RETU Consulting Limited is a financial-services consultancy and is not itself an SFC-licensed corporation. Where an engagement involves a regulated activity, that activity is carried out by the appropriately licensed entity.