Hong Kong TCSP License

Since March 2018，To comply with the highest international anti-money laundering (AML) and counter-terrorism financing (CTF) standards，Hong Kong fully implements the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Chapter 615)。The law clearly stipulates，Any person carrying on trust or company services business in Hong Kong，must be addressed toHong Kong company registration处（Companies Registry）Apply and getTrust or Company Service Provider License (TCSP License)。Operating without a license is a serious criminal offence。The following is a detailed guide to applying for a TCSP license.。

one、What is a TCSP license? What are the core business scopes?

TCSP (Trust or Company Service Provider) license is a statutory license issued by the Hong Kong Companies Registry。If you or your business provides any one or more of the following services as a business in Hong Kong，All must apply for a TCSP license：

• Company secretarial services：Acting or arranging for others to act as company secretary or director of a corporation；
• Company establishment services：Assistance in establishing Hong Kong companies or other legal entities；
• address service：Providing a registered office for a corporation or partnership、business address、Correspondence or administrative address；
• Trust and custody services：Act as trustee of an Express Trust，or act as someone’s nominee shareholder (Nominee shareholder)；
• Partner services：Acting as or arranging for others to act as partners in a partnership, etc.。

two、Statutory exemptions (who does not need to apply?)

in Hong Kong，Only a very small number of professionals or institutions are subject to other equivalent or more stringent regulatory mechanisms，Can be exempted from applying for TCSP license under certain conditions：

• Institutions recognized by the Hong Kong Monetary Authority (HKMA) (such as licensed banks)；
• A licensed corporation licensed by the Securities and Futures Commission of Hong Kong (SFC) (provided that the TCSP service is ancillary to its main regulated business)；
• Hong Kong certified public accountants or practicing corporations as defined in the Professional Accountants Ordinance (regulated by the Accounting and Financial Reporting Council)；
• Hong Kong lawyers and foreign lawyers as defined in the Legal Practitioners Ordinance (supervised by the Law Society of Hong Kong)。

three、Core requirements for TCSP license application

1. Legal business entity and address：The applicant must be an entity holding a valid Hong Kong Business Registration Certificate (BR) (usually a limited company incorporated in Hong Kong)。Overseas companies such as BVI are not allowed to operate without a license without a Hong Kong BR.。Must have a local physical office address in Hong Kong。

2. Fit and Proper Test：All directors of the company、Partners and ultimate owners (individuals holding more than 25% of the shares or controlling interests) must pass strict background checks，Make sure there are no serious financial、Fraud、Money laundering and other criminal offense records，Have good business integrity。

3. Establishment of Compliance and Money Laundering Reporting Officer：The applicant company must appoint aCompliance Officerand oneMoney Laundering Reporting Officer (MLRO)。Depends on company size，Both positions can be filled by the same person，Responsible for enforcing internal AML/CTF policies and reporting suspicious transactions to authorities。

4. Anti-money laundering system and business plan：A practical anti-money laundering compliance manual must be developed (AML/CTF Systems)，Covers Customer Due Diligence (KYC)、risk assessment、Core mechanisms such as transaction monitoring and record keeping。

Four、Application process and official approval process

first step：Submit application form and materials。Complete the official "Form TCSP1" and Supplementary Information Sheet (TCSP1-SIS)，And complete the "Fit and Proper Statement" (Form TCSP4 or TCSP5) for each director and ultimate owner.。together with business registration certificate、Company structure chart、Compliance policies, etc. are submitted toCompanies Registry。

Step 2：Interviews and competency assessments。During the review of documents by the Companies Registry，The Compliance Officer/Head of the applicant company will usually be asked to attend the interview，To assess their familiarity and practical ability with Hong Kong’s anti-money laundering regulations。

Step 3：wholesale license。All documents are available、After passing the background check and interview，The Companies Registry will usually be located at 2to 2.5 months Complete approval and issue license within。TCSP license starts from the date of issuance Validity period is usually 3 years。

five、2025Annual official fee details

To apply for a TCSP license, you need to pay the statutory application fee to the government (the paid fee will not be refunded)：

• New license application fee：Hong Kong dollar 3,440 Yuan。
• Fit and proper assessment fee：Each person subject to assessment (e.g. directors、ultimate owner)，Additional Hong Kong dollars are required for each 975 Yuan。
• License renewal fee (every 3 years)：Application fee HKD 2,910 Yuan (plus per person 975 a fit and proper person assessment fee of RMB yuan)。

six、Strict compliance obligations after licensing

Obtaining a license is by no means a one-and-done thing，The Companies Registry will conduct continuous monitoring of TCSP licensees，Even on-site inspections。The responsibilities that licensees must fulfill include:：

• Perform KYC and CDD：Before establishing a business relationship with a customer，Strict customer due diligence must be conducted，Identifying the Ultimate Beneficial Owner (UBO)，and implement continuous monitoring based on risk levels.。
• Keep records for more than 5 years：Keep all customer identity information properly、Due diligence documents and transaction records。
• Reporting changes to personnel and structure：Any change of business address，or add new directors、ultimate owner，Must be within 1 month before or after the change，Report to the Registrar using "Form TCSP3" or "Form TCSP6"。It is illegal to add new directors without approval。

seven、FAQ (FAQ)

Q1：If you are operating company secretarial or trust business without a license，What will be the consequences?
A1：Hong Kong adopts a "zero tolerance" attitude towards this。Operating TCSP business without a license is a serious criminal offense，Once convicted，The maximum penalty that can be imposed fined HK$100,000 and jailed for 6 months。

Q2：My TCSP license is about to expire，How far in advance do I need to apply for renewal?
A2：The licensee must At least 60 days or before Submit renewal application。If the renewal is missed, the license will become invalid.，You must immediately cease all secretarial and trust services，and resubmit a new application。

Q3：How do customers know whether our company holds a legal TCSP license?
A3：The Hong Kong Companies Registry has established a public “Register of Trust or Company Services Licensees”。Anyone can log in to the official website (www.tcsp.cr.gov.hk)，Enter your company's Chinese and English name to verify the license status and number in real time。

The application for a Hong Kong TCSP license is not only about obtaining a business license，It is also a comprehensive test of the company’s anti-money laundering and risk control capabilities.。Facing complicated forms、Rigorous interviews and compliance pressure after obtaining a license，It is wise to seek protection from professional organizations。Leading business consultantWith profound practical experience in Hong Kong corporate law and AML compliance，Provide you with policy drafting、Material pre-review、Interview coaching to post-licensing compliance maintenanceOne-stop consulting service，Help you obtain a license without any worries，Steady expansion of corporate service territory。