AML/CFT Compliance Services for
TCSP Licensees
Comprehensive regulatory compliance support for Trust or Company Service Provider licensees in Hong Kong — from risk assessment to independent audit and staff training.
Since the TCSP licensing regime came into effect on 1 March 2018 under the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (AMLO, Cap. 615), every Trust or Company Service Provider (TCSP) licensee in Hong Kong has been subject to a comprehensive and growing set of AML/CFT obligations. The revised Guideline on Anti-Money Laundering and Counter-Financing of Terrorism for TCSP Licensees, which became effective on 3 March 2025, significantly raised the bar — introducing mandatory Institutional Risk Assessments (IRA), tightening Customer Due Diligence (CDD) timelines, and formalising requirements that the Companies Registry (CR) is now actively enforcing through inspections and enforcement actions.
Non-compliance is not a theoretical risk. The CR’s November 2025 “Points to Note” guidance identified the absence of a properly documented IRA and deficiencies in written AML/CFT policy statements as the most common findings during TCSP licensee inspections. Penalties under the AMLO include pecuniary fines of up to HKD 500,000, public reprimands, remedial orders, and licence suspension or revocation.
EQC Compliance Advisory brings its proven track record in AML/CFT compliance — built across 250+ CPA practice inspection engagements and backed by Big 4 audit experience — to the TCSP sector. Our team of qualified CPAs and compliance professionals understands both the technical regulatory requirements and the practical realities of running a TCSP practice in Hong Kong. Whether you are a newly licensed TCSP seeking to build your compliance framework from the ground up, or an established licensee preparing for a CR inspection, EQC offers targeted, cost-effective services that go beyond generic templates to deliver compliance frameworks that are genuinely inspection-ready.
Our Three TCSP AML / CTF Services
1. Independent AML / CTF Audit
An objectivei, independent review of your AML / CTF systems, controls, and written policies – conducted by qualified professionals to identify gaps before the Companies Registry does. Every TCSP Licensee is required to subject its AML / CTF Framework to independent review and the CR assesses the quality and independence of that review during inspections.
2. AML / CTF Training for TCSP Staff
Structured, practical AML/CFT training programmes for TCSP licensees and their staff, covering the latest regulatory developments, typologies, and compliance obligations under the March 2025 revised Guideline. Training must be conducted at least annually and records must be retained for CR inspection.
3. AML / CTF Complaince Consultancy
End-to-end consultancy covering Institutional Risk Assessments (IRA), KYC/CDD procedures, written AML/CFT policies, sanctions screening frameworks, and ongoing compliance support for TCSP licensees. Our consultancy service addresses every material obligation under Cap. 615 — from the initial design of your compliance framework to ongoing support as the regulatory landscape evolves.
Regulatory Timeline for TCSP Licensees
Date
Regulatory Milestone
1 March, 2018
TCSP licensing regime introduced under AMLO Cap. 615. All persons providing registered office, company secretarial, nominee director/shareholder, or trust services in Hong Kong required to hold a TCSP licence.
Written AML/CFT policy, CDD/KYC procedures, sanctions screening, STR reporting, and annual staff training obligations come into effect for all TCSP licensees.
3 March, 2025
Revised TCSP AML/CFT Guideline effective. Institutional Risk Assessment (IRA) formally required. CDD identity verification window reduced from 60 to 30 working days. Enhanced beneficial ownership requirements introduced.
November 2025
CR issues “Points to Note” guidance identifying IRA absence and written policy deficiencies as the most common inspection findings among TCSP licensees.
Ongoing
Annual AML/CFT staff training required. Sanctions screening at minimum monthly. IRA to be reviewed every 2 years or upon any material change to the business or risk environment.
Why Choose EQC?
Big 4 Audit Pedigree: Our lead consultant brings over a decade of Big 4 audit experience, ensuring your compliance framework meets the highest professional standards expected by the Companies Registry.
Experienced: Unmatched practical experience across CPA practice and regulatory inspection contexts, now applied directly to the TCSP sector. We know what inspectors look for — because we have seen it firsthand.
Current Regulatory Intelligence: We stay current with every CR circular, guideline revision, and enforcement action — so you don’t have to. Our advice reflects the latest regulatory expectations, not last year’s templates.
Tailored, Not Templated: Every IRA, policy manual, and training programme is customised to your specific client base, service scope, and risk profile. Generic compliance documents do not pass CR inspections — ours do.