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Hong Kong TCSP Trust and Company Services License

Organize applications and ongoing responsibilities in accordance with the TCSP licensing system implemented on March 1, 2018。

1. Hong Kong TCSP Trust and Company Services License:Institutional background and legal basis

Hong Kong’s trust or company service provider (TCSP) system is based on the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Chapter 615)。Any person providing company incorporation in the form of business in Hong Kong、Director or Secretary Arrangement、Registered address、Trust management and other designated services,In principle, you must first obtain a TCSP license issued by the Registrar of Companies,unless subject to statutory exemption。

License review is not equivalent to ordinary company registration。applicant、per partner、Directors and ultimate owners subject to fit and proper vetting;Service scope、Customer type、agency arrangement、Client fund contact methods and cross-border referral relationships should be clarified before application。The license is generally valid for three years,Application for license renewal should be submitted at least 60 days before expiry。

Important tips:As long as statutory TCSP services are provided on a business basis,Licensing requirements should usually be assessed first。

2. Core regulatory information

regulatory agency

Hong Kong Companies Registry
The specific acceptance units and authorities shall be subject to the latest public information of the Hong Kong Companies Registry.。

regulatory path

Trust or Company Service Provider (TCSP) License
As long as statutory TCSP services are provided on a business basis,Licensing requirements should usually be assessed first。

Check the key points

License Scope and Ongoing Obligations
The content has been combined with the disclosure rules of regulatory agencies、Cross-check application material structure and actual business process。

3. Business scope and license boundaries

Scope description

The following content is used to delineate the project scope of Hong Kong TCSP trust and company services license;The final decision should be based on actual business and official approval.。

Establish a company or legal person

Application documents should describe the products of the established company or legal person、client、channel、transaction process、Revenue model and controls。

Provide registered address、Director or Secretary Arrangement

Application documents should indicate the registered address provided、Products arranged by director or secretary、client、channel、transaction process、Revenue model and controls。

Trust or company administration

Application documents should describe the products administered by the trust or company、client、channel、transaction process、Revenue model and controls。

4. Application subject、capital、people and places

Check before applying

The Hong Kong Companies Registry usually obtains the、personnel、Review of business authenticity and risk control;Material depth will vary from project to project。

official information:Hong Kong Companies Registry。The latest form should be double-checked before submission.、cost、Timeframes and technical requirements。

business plan

Describe the proposed establishment of a company or legal person item by item、Provide registered address、Director or Secretary Arrangement、Trust or company administration,including customers、area、channel、Products and funding flows。

Equity and Management

Disclosure Shareholders、ultimate controller、Directors and key personnel,and be prepared to be honest、Proof of experience and financial resources。

Governance and Control

Establish division of responsibilities、conflict of interest、complaint、outsourcing、business continuity、Cybersecurity and financial controls。

AML/CFT Framework

Establish customer due diligence based on risk assessment、Continuous monitoring、Sanctions Screening、suspicious transaction report、Record keeping and training mechanisms。

Capital and financial resources

The TCSP licensing system itself does not set a uniform minimum paid-up capital for all applicants;Applicants must still prove that the business is genuine、Governance and AML/CFT controls enforceable,and undertake company establishment、premises、personnel、System and renewal costs。

Key People and Governance

individual applicant、Partner、Directors and ultimate owners subject to fit and proper vetting;The business should make it clear who is responsible for customer due diligence、Beneficial owner identification、Sanctions Screening、Suspicious transaction reporting and record keeping。

Office and local content

office、Registered address and record keeping location should be checked separately。If the regulatory authority requires local substance,A mail-only virtual address must not be used as a substitute for actual management、customer service、System control and file access arrangements。

5. Government charges and project budgets

The budget should differentiate between statutory expenses、Capital or margin、Company and premises costs、Personnel costs and professional service fees。If there is no official basis, do not write a fixed total price or guarantee the betting period.。

budget itemsBilling basisCheckpoints
Regulatory application and annual feesBy license type、Scope of authority、Number of applicants and key personnel,and calculation of the current fee schedule of the competent authority.。Only quote the current fee schedule of the competent authority;Third-party service fees must not be packaged as government fees。
capital、Security deposit and insuranceThe TCSP licensing system itself does not set a uniform minimum paid-up capital for all applicants;Applicants must still prove that the business is genuine、Governance and AML/CFT controls enforceable,and undertake company establishment、premises、personnel、System and renewal costs。Capital is not a service fee,Nor shall it be satisfied by temporary borrowings or funds from unexplained sources.。
Company establishment and statutory maintenanceAccording to registration place、share capital、registered agent、secretary、Registered address、Separate quotations for annual reports and tax returns。The establishment of a company does not mean the approval of a license or the opening of a bank account.。
Office and personnelby lease、deposit、area、use、local salary、Visa and residency requirement accounting。First confirm the substantive requirements for regulatory acceptance,Sign a new lease or hire staff。
system、Systems and professional servicesAML/KYC calculation based on business complexity、Sanctions Screening、Transaction monitoring、network security、audit、legal advice、Translation and notarization。The quotation should specify the scope、hypothesis、Third-party fees and number of replacement parts。

6. Application process and review cycle

The length of the process depends on the complexity of the business、Data completeness and inquiries from the Hong Kong Companies Registry or receiving agency,It is not appropriate to promise a fixed time for approval。

first step:Delineate regulated activities

put product、client、area、Channels and fund flows are mapped to the scope of the Trust or Corporate Service Provider (TCSP) license。

Step 2:Design subject and governance structure

Determine the applicant、Equity、director、key personnel、Office space and outsourcing arrangements。

Step 3:Prepare application and institutional documents

Prepare business plan、financial forecast、Organizational structure、Risk assessment and various compliance policies。

Step 4:Submit and receive review

Submit an application to the Hong Kong Companies Registry,Reply to addendum、Interview、System demonstration or on-site inspection。

Step 5:Approval and continued compliance

Check license conditions,Complete capital before starting business、personnel、system、Client assets and reporting arrangements。

7. Licensed、Renewal and ongoing supervision

Licensees must continuously maintain customer due diligence and transaction records、Update risk assessment,and on the board of directors、ultimate owner、When the business address or business information changes, notify the registration office as required。License renewal is not automatic;Overdue、Information is inconsistent or the person concerned is no longer appropriate,This may affect license renewal or lead to disciplinary action。

8. 2023–2026 Regulatory Updates and Official Information

Launch of company secretary in 2026、Registered address、Before Nominee Director or Trust Administration Services,Legal entities should be checked against the TCSP licensee register first、license number、Validity period and approved operation information。General business registration、Being an accountant or lawyer cannot always replace the TCSP license.,Whether or not to be exempted must be determined on a case-by-case basis in accordance with Chapter 615。

Official verification entrance:Hong Kong Companies Registry:Trust or company service provider licensing regime

Information update instructions:regulatory scope、capital、personnel、cost、Time limits and continuing obligations subject to adjustment,Before formal application, the current rules of the competent authority should be followed、The form and case approval shall prevail.。

9. Customer FAQ

Hong Kong’s trust or company service provider (TCSP) system is based on the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Chapter 615)。Any person providing company incorporation in the form of business in Hong Kong、Director or Secretary Arrangement、Registered address、Trust management and other designated services,In principle, you must first obtain a TCSP license issued by the Registrar of Companies,unless subject to statutory exemption。 License review is not equivalent to ordinary company registration。applicant、per partner、Directors and ultimate owners subject to fit and proper vetting;Service scope、Customer type、agency arrangement、Client fund contact methods and cross-border referral relationships should be clarified before application。The license is generally valid for three years,Application for license renewal should be submitted at least 60 days before expiry。

The focus of supplements usually focuses on actual control、ultimate beneficial owner、Director resume、Right to use business address、Business plan and executable AML/CFT system。In practice, customers should also be prepared to accept、Beneficial owner identification、Sanctions Screening、Suspicious transaction upgrade、Record keeping and employee training samples,The certification system is not a universal template。

Licensees must continuously maintain customer due diligence and transaction records、Update risk assessment,and on the board of directors、ultimate owner、When the business address or business information changes, notify the registration office as required。License renewal is not automatic;Overdue、Information is inconsistent or the person concerned is no longer appropriate,This may affect license renewal or lead to disciplinary action。

Launch of company secretary in 2026、Registered address、Before Nominee Director or Trust Administration Services,Legal entities should be checked against the TCSP licensee register first、license number、Validity period and approved operation information。General business registration、Being an accountant or lawyer cannot always replace the TCSP license.,Whether or not to be exempted must be determined on a case-by-case basis in accordance with Chapter 615。 See the latest rulesHong Kong Companies Registry:Trust or company service provider licensing regime

The system should be based on the company's customers、Country or region、product、Channel and transaction characteristics shape enterprise risk assessment,and fall to customer due diligence、Beneficial owner identification、Continuous monitoring、Sanctions and PEP Screening、Suspicious transaction escalation and reporting、record keeping、Staff training and independent testing。Directly apply common templates、There is no threshold basis or the operation record cannot be displayed,Usually insufficient to prove that the system can actually operate。

Don’t judge based on just a single number。Legal minimum capital should be distinguished、regulatory capital、margin、Insurance、Protection of customer assets and sufficient financial resources to sustain operations,And check the current rules of the Hong Kong Companies Registry according to the scope of application and business scale。Source of funds、Financial forecasts and stress scenarios should also be interpretable and verifiable。Special attention should also be paid to this project:As long as statutory TCSP services are provided on a business basis,Licensing requirements should usually be assessed first。

The answer depends on local laws、Eligibility for a trust or company service provider (TCSP) license、Planned activities and outsourcing model。Even if the rules do not uniformly provide for a certain position or area,Hong Kong Companies Registry may still focus on decision、Record、customer service、Whether risk management and regulatory communications have sufficient local substance;Before leasing space or hiring personnel,Case requirements should be checked first。

Review time is subject to application completeness、business complexity、Key personnel qualifications、Regulatory inquiries、Interviews or system demonstrations and third-party attestation of impact,It is not appropriate to promise a fixed date for approval。The project plan should separately list preparation、submit、Supplementary parts、Technical rectification and post-approval commissioning phase,and retain sufficient buffering;Only the competent authority can decide whether to accept and approve。

Usually not。Applicants should complete supplier due diligence,Describe data flow、service level、Audit right、Subcontract、information security、Business continuity and exit arrangements,and retain the rules、threshold、Alarm handling and major accident supervision capabilities。Whether outsourcing is ultimately allowed and what notification or approval is required,Should be checked according to the current regulations of the Hong Kong Companies Registry。

Already submitted、Company registration under review or completion is described as approved。Formal commencement of regulated activities、Actively solicit customers、Before collecting client funds or issuing potentially misleading licensing claims,It should be confirmed that the license has taken effect、The business does not exceed the approved scope,And also check the cross-border marketing rules of the target customer’s location。

Common matters include renewal or annual fees、Regulatory filing、Financial or compliance audit、training、record keeping、Complaint handling、Client Assets and Capital Monitoring,and equity、director、key personnel、address、Business scope、System and major incident notification or prior approval。A compliance calendar and change approval process should be established,and obtain regular rule updates from the Hong Kong Companies Registry。

should beHong Kong Companies RegistryCurrent regulations issued、Application form、guidelines、The fee schedule and announcement shall prevail。88MSO page is used to help organize questions and materials,Not representing regulatory agencies,Nor can it replace local lawyers、Opinions from tax consultants or competent authorities on individual cases。

You can continue reading based on project boundariesHong Kong Money Lenders (ML) LicenseHong Kong VASP Virtual Asset Service License。These pages are used to compare different regulatory pathways or supporting services;Do they need to be processed at the same time?,real product、Customer area、The contracting entity and capital flow shall prevail.。

Government or competent authority fees should correspond to official fee schedules、Payment notice or receipt;capital、margin、Insurance、office、personnel、system、audit、law、Translation and consulting services are independent budget items。Formal quotations should specify the currency、taxes、third party expenses、Applicable Assumptions and Exclusions。

The applicant should be confirmed first、Legal registered address、actual management location、Differences Between Customer Reception Locations and Record Keeping Locations,Recalculation of registration fees、agent or secretary、rent、deposit、furnish、communication、Insurance、Visas and local personnel。Rent an office first and then determine regulatory boundaries,May cause unrecoverable costs。