TCSP License: How to Become a Trust or Company Service Provider

By Easy Biz Team at Easy Solution (HK) Limited · Published 5 July 2026 · 7 min read

What Is a TCSP License?

A Trust or Company Service Provider (TCSP) license is a regulatory authorization issued by the Companies Registry under the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (AMLO, Cap. 615). Since 1 March 2018, any person carrying on a trust or company service business in Hong Kong must obtain this license before commencing operations.

The TCSP licensing regime was introduced to bring Hong Kong in line with the standards set by the Financial Action Task Force (FATF), the global body for anti-money laundering standards. The regime ensures that service providers who form companies, act as nominee directors or shareholders, and provide trust services are subject to proper regulatory oversight.

Who Needs a TCSP License?

A TCSP license is required by anyone who, in the course of business, provides any of the following services:

• Company formation services — acting as an agent for the formation of companies
• Company secretary services — providing a registered office, business address, or accommodation for companies
• Acting as (or arranging for another person to act as) a nominee director or shareholder
• Trust services — acting as or arranging for a professional trustee
• Corporate directorship services — providing corporate directors or company secretary services

If your business provides any of these services, you must hold a valid TCSP license. Operating without one is a criminal offence punishable by a fine of up to HKD 100,000 and imprisonment for up to 6 months.

TCSP License Requirements

To obtain a TCSP license, an applicant must satisfy the Registrar of Companies that they meet the following criteria:

• Be a fit and proper person — assessed based on integrity, financial stability, competence, and character
• Submit a completed application form (Form TCSP 1) with all required supporting documents
• Provide details of all directors, partners, and beneficial owners (defined as persons holding 25%+ of voting rights or ownership)
• Have appropriate AML/CFT policies and procedures in place
• Appoint a qualified Compliance Officer (CO)
• Pay the application fee (HKD 2,300) and annual license fee (HKD 2,300)

The application review process typically takes 3–5 months, during which the Companies Registry conducts background checks in consultation with the Hong Kong Police Force and other authorities.

Compliance Officer (CO) Requirements

Every TCSP licensee must appoint a Compliance Officer (CO) who serves as the primary point of contact for the Companies Registry on all AML/CFT matters. The CO must be:

• A senior person within the organisation — typically a director, partner, or senior manager
• Sufficiently senior and independent to carry out compliance duties effectively
• Knowledgeable about the AMLO and its subsidiary legislation, including the Guideline on AML/CFT issued by the Companies Registry
• Approved by the Companies Registry (the CO's details are submitted as part of the license application)

The CO is personally responsible for ensuring the firm's compliance with AML/CFT obligations, including customer due diligence, record-keeping, suspicious transaction reporting, and staff training.

AML/CFT Policies & Procedures

TCSP licensees must implement robust Anti-Money Laundering and Counter-Terrorist Financing (AML/CFT) policies and procedures. These must include:

• Risk assessment framework — a documented assessment of the money laundering and terrorist financing risks specific to the firm's business
• Customer Due Diligence (CDD) procedures — for identifying and verifying all clients and their beneficial owners
• Enhanced Due Diligence (EDD) — for high-risk clients, including Politically Exposed Persons (PEPs) and clients from high-risk jurisdictions
• Sanctions screening — checking clients against the UN Security Council Consolidated List and other sanctions lists
• Suspicious Transaction Reporting (STR) — procedures for identifying and reporting suspicious transactions to the Joint Financial Intelligence Unit (JFIU)
• Record-keeping — retaining CDD records, transaction records, and supporting documents for at least 5 years
• Staff training — regular AML/CFT training for all employees
• Independent audit — periodic independent review of the AML/CFT framework

CDD Systems and Procedures

Customer Due Diligence is the cornerstone of TCSP compliance. Before establishing a business relationship, a TCSP licensee must:

1. Identify the customer — obtain full name, date of birth, nationality, and identification document details
2. Verify identity — review official identification documents (HKID, passport, certificate of incorporation, business registration)
3. Identify beneficial owners — determine who ultimately owns or controls the customer (25% threshold or more)
4. Understand the purpose — obtain information on the nature of the business relationship and intended transactions
5. Conduct ongoing monitoring — periodically review and update client information
6. Screen for PEPs and sanctions — check whether the client or beneficial owner is a PEP or on any sanctions list

New Application vs Buying an Existing TCSP Company

Factor	Buy Existing	Apply New
Timeline	3–5 weeks	3–5 months
Cost	HKD 100K–200K	HKD 30K–60K (compliance + filing)
Compliance systems	Already in place	Must build from scratch
Compliance Officer	Incumbent CO may stay	Must appoint and register
Success rate	Near-guaranteed	Subject to Registry approval

How to Buy an Existing TCSP Company

Acquiring an existing TCSP-licensed company through share transfer is the fastest route to operating as a trust or company service provider. The process involves:

Step 1: Identify a suitable licensed company and sign a non-disclosure agreement.

Step 2: Conduct due diligence — verify the license status on the Companies Registry's TCSP register, review compliance records, check for any disciplinary actions, and confirm the scope of the license.

Step 3: Sign the Sale & Purchase Agreement and pay the deposit.

Step 4: Complete the share transfer — file the Instrument of Transfer with the Companies Registry. Pay stamp duty of 0.2% under the Stamp Duty Ordinance (Cap. 117).

Step 5: Update directors, shareholders, secretary, and the Compliance Officer. File Form NCA1 with the Companies Registry.

Step 6: Notify the Companies Registry of the change in ownership, directors, and CO within 1 month. No new license application is typically required.

Step 7: Take over the business. The TCSP license continues under the new ownership.

Frequently Asked Questions

Is the TCSP license transferable to another person?

No. The license is attached to the licensee entity. To "transfer" the license, you acquire the licensed company through a share transfer. The license remains valid for the entity under new ownership, subject to notifying the Companies Registry.

What are the ongoing obligations for a TCSP licensee?

TCSP licensees must maintain AML/CFT compliance, conduct CDD on all clients, keep records for 5 years, report suspicious transactions, undergo periodic inspections by the Companies Registry, and renew the license annually.

Can a non-Hong Kong resident apply for a TCSP license?

Yes, but the applicant must have a Hong Kong entity (company or partnership) and a physical presence in Hong Kong. All directors, partners, and beneficial owners are subject to fit and proper checks.