Unit 1605, 16/F, West Tower, Shun Tak Centre,168-200 Connaught Road Central, Sheung Wan, Hong Kong
Application for TCSP Licence
Hong Kong, a premier international financial centre, attracts businesses from around the globe. Its robust legal system and strategic location make it an ideal place to incorporate and operate a company. As of the end of 2025, there was a record high of more than 1,500,000 local and re-domiciled companies registered with the Hong Kong Companies Registry (CR) serviced by an ecosystem of more than 7,000 Trust or Company Service Provider (TCSP) licensees.
The TCSP licensing regime is administered by the CR under the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (AMLO) (Cap. 615). Any person who wishes to carry on a trust or company service business in Hong Kong must obtain a TCSP licence and comply with the statutory requirements. These include customer due diligence, record-keeping, and ongoing obligations such as notifying the CR of any changes in particulars.
What is a TCSP business?
TCSP business is often commonly referred to as "company secretary services". But in fact, it encompasses a much broader range of professional activities. Below are the major categories of a TCSP business:
Business Category(業務類別) | Scope of TCSP businesses(業務範圍) |
|---|---|
Company Formation | Setting up companies or other legal entities for clients. |
Corporate Officer Services | Acting as (or arranging for someone else to act as) a company director, company secretary, partnership partner, or similar position for other legal structures. |
Registered Address Services | Providing a registered office, business address, or correspondence address for a company, partnership, or other legal entity/arrangement. |
Trust & Nominee Services | Acting as (or arranging for someone else to act as) a trustee for an express trust, or serving as a nominee shareholder for someone (unless the shares are in a company listed on a recognized stock market). |
Major requirements on TCSP Licensing
Requirement(要求) | Details(詳細說明) |
|---|---|
Fit and Proper Test | All directors, ultimate owners, and every relevant person of the TCSP must pass the fit and proper test conducted by the CR. |
Key Personnel | Appoint a local Compliance Officer (CO) and Money Laundering Reporting Officer (MLRO) to oversee AML/CFT compliance. |
Business Premises | Maintain a business premises in Hong Kong suitable for conducting business, processing transactions, and securely storing documents, data, and records. |
Ongoing Obligations | Notify the CR of any changes in particulars, including: business name, contact details, directors, ultimate owners, CO, MLRO, and any change affecting fit and proper status. |
AML/CFT Compliance | Comply with all requirements of the AMLO and AML guidelines issued by the CR, including customer due diligence, screening, and record-keeping. |
Licence Renewal | The TCSP licence is valid for 3 years and must be renewed before expiry to continue operating lawfully. |
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繁｜簡｜EN
Comparison of Different Fund Structures
➤ Define a shareholding structure where all directors and ultimate owners meet the fit and proper requirements
➤ Appoint a Compliance Officer (CO) and Money Laundering Reporting Officer (MLRO)
➤ Establish a suitable business premises in Hong Kong for operations and record-keeping
➤ Develop your business plan and define your line of business
➤ Formulate your AML/CFT policy in accordance with statutory requirements
What ComplianceOne can do for you
ComplianceOne offers one-stop registration assistance, including:
✔ Incorporating a Hong Kong limited company
✔ Recruiting CO, MLRO, and other key staff
✔ Drafting business plans and internal control policies
✔ Designing effective AML/CFT policies, encompassing Customer Due Diligence (CDD), ongoing monitoring, and suspicious transaction reporting procedures
✔ Submitting license applications to regulator on behalf of clients
✔ Liaising with regulators on behalf of clients throughout the application process
✔ Assisting with corporate bank account opening and arranging the necessary deposits for trust company registration
✔ Preparing the company and key personnel for regulatory interviews
✔ Providing compliance training to senior management and staff
✔ Providing access to a reputable AML/CFT name screening platform – Screen-X AML/CRM Solutions, powered by Acuris Risk Intelligence (ARI), to help meet regulatory requirements through automated screening tools
Timeline
Under normal circumstances, the entire process takes approximately 3-4 months. This includes 1 month for company incorporation and preliminary preparations, 1 month for recruiting a suitable CO and MLRO (if needed), and 2 to 3 months for the regulatory authority to process the application. ComplianceOne will assist in addressing inquiries from the regulatory authority throughout the process.
External Reference
1.Guideline on Licensing of Trust or Company Service Providers
https://www.tcsp.cr.gov.hk/tcspls/portal/guide/1033/eng/TCSP_G1_revised_May2025-e.pdf
2.Guideline on Anti-Money Laundering and Counter-Financing of Terrorism (For Trust or Company Service Provider Licensees)
3.Guideline on Imposition of Pecuniary Penalty (March 2018)
https://www.tcsp.cr.gov.hk/tcspls/portal/guide/61/chi-t/TCSP_G3-c.pdf