Understanding the Hong Kong TCSP licence

What Is a TCSP Licence in Hong Kong?

A TCSP licence is mandatory under the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615) for anyone carrying on a trust or company service business in Hong Kong. This requirement has applied since 1 March 2018. Providing these services without a valid licence is a criminal offence.

The tcsp licence hong kong requirement covers anyone who, in the ordinary course of business, forms companies, acts as a company secretary, provides a registered office address, or acts as or arranges for another person to act as a trustee or nominee shareholder. You must hold a licence from the Registrar of Companies unless an exemption applies.

Trust or Company Service Provider Licence

A trust or company service provider licence authorises activities including company formation, company secretarial work, acting as a director or nominee shareholder for another person, and providing a registered office or correspondence address. The Registrar of Companies issues the licence, which is valid for three years.

Anti-Money Laundering Ordinance Cap. 615

The Anti-Money Laundering Ordinance Cap. 615 governs TCSP licensing in Hong Kong. It imposes anti-money laundering and counter-terrorist financing obligations on licensees, including customer due diligence and record-keeping requirements. Under this ordinance, the Registrar of Companies is the licensing authority for TCSPs.

Hong Kong TCSP Register

The Hong Kong TCSP register is a public, searchable database of all licensed trust or company service providers. The Companies Registry maintains the register under the Anti-Money Laundering and Counter-Terrorist Financing Ordinance. Check the register before engaging any TCSP.

TCSP Licence Renewal

A TCSP licence is valid for three years and must be renewed before it expires. The Registrar of Companies will not renew the licence automatically; the licensee must submit a renewal application. Customer due diligence and record-keeping obligations apply continuously throughout the licence period.

Penalties for Non-Compliance

Carrying on a trust or company service business without a licence is an offence. On conviction, a person is liable to a fine of up to HK$100,000 and imprisonment for up to six months. The public register allows potential clients to verify that a provider is properly licensed.