TCSP regulatory compliance and inspection readiness
AML / CFT Compliance Services for TCSP Licensees
Comprehensive regulatory compliance support for Trust or Company Service Provider licensees in Hong Kong — from risk assessment and written policies 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, effective from 3 March 2025, raised the bar by introducing mandatory Institutional Risk Assessments (IRA), tightening Customer Due Diligence (CDD) timelines, and formalising requirements that the Companies Registry (CR) is 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 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 AML/CFT compliance experience built across more than 250 CPA-practice inspection engagements and supported by Big 4 audit experience to the TCSP sector. Whether you are a newly licensed TCSP building a framework from the ground up or an established licensee preparing for a CR inspection, EQC provides targeted support intended to turn regulatory requirements into practical, documented, inspection-ready processes.
Ongoing monitoring matters: accepted clients and their stakeholders should be supported by real-time sanctions and adverse-information searches at least monthly. This should be implemented promptly, as evidence of searches cannot be backdated.
Our Three TCSP AML / CTF Services
Independent AML / CTF Audit
An objective, independent review of your AML/CFT systems, controls, and written policies, carried out by qualified professionals to identify material gaps before the Companies Registry does. TCSP licensees are expected to subject their AML/CFT framework to independent review, and the CR assesses the quality and independence of that review during inspections.
AML / CTF Training for TCSP Staff
Structured, practical AML/CFT training for TCSP licensees and staff, covering current regulatory developments, typologies, and obligations under the March 2025 revised Guideline. Training should be conducted at least annually and records retained for CR inspection.
AML / CTF Compliance Consultancy
End-to-end consultancy covering Institutional Risk Assessments, KYC/CDD procedures, written AML/CFT policies, sanctions-screening frameworks, and ongoing compliance support. The work addresses material obligations under Cap. 615, from the design of a compliance framework through to practical support as the regulatory environment evolves.
Regulatory Timeline for TCSP Licensees
| Date | Regulatory milestone |
|---|---|
| 1 March 2018 | TCSP licensing regime introduced under AMLO Cap. 615. Persons providing registered-office, company-secretarial, nominee director/shareholder, or trust services in Hong Kong are required to hold a TCSP licence. Written AML/CFT policy, CDD/KYC procedures, sanctions screening, STR reporting, and annual staff-training obligations apply. |
| 3 March 2025 | Revised TCSP AML/CFT Guideline effective. Institutional Risk Assessment formally required; CDD identity-verification window reduced from 60 to 30 working days; enhanced beneficial-ownership requirements introduced. |
| November 2025 | CR “Points to Note” guidance identifies the absence of an IRA and deficiencies in written policy statements as common inspection findings among TCSP licensees. |
| Ongoing | Annual AML/CFT staff training required; sanctions screening at least monthly; IRA reviewed every two years or on a material change to the business or risk environment. |
Why Choose EQC?
Big 4 Audit Pedigree
Our lead consultant brings more than a decade of Big 4 audit experience, supporting frameworks designed to meet the professional standards expected by the Companies Registry.
Experienced and Practical
Practical experience across CPA-practice and regulatory-inspection contexts is applied directly to TCSP compliance work, with a clear focus on what inspectors expect to see in the file.
Current Regulatory Intelligence
EQC monitors CR circulars, guideline revisions, and enforcement developments so the advice reflects current regulatory expectations rather than generic or outdated templates.
Tailored, Not Templated
Each IRA, policy manual, and training programme is adapted to the licensee’s client base, service scope, and risk profile, with clear evidence of the practice’s own decisions and controls.
Related Regulatory Insights
Practical reading from EQC’s Regulatory Insights for owners, compliance officers, and reviewers who need to translate screening, client acceptance, and evidence requirements into defensible working practices.
Six Questions on PEPs Before Client Acceptance
A practitioner-focused reminder that PEP screening is the start of a documented client-risk decision, not merely a search result.
CARF Data Lineage Playbook
Why compliance readiness starts with traceable information, ownership, and evidence before a reporting or filing deadline arrives.
One Evidence Architecture, Three Deadlines
A practical view of how organisations can align regulatory changes, documentation, and digital evidence in a single operating approach.
Prepare Your TCSP Practice for the Next Compliance Review
Discuss an independent AML/CFT audit, Institutional Risk Assessment, training programme, written policy update, or ongoing monitoring support tailored to your TCSP practice.