Application for a Trust or Company Service Provider (“TCSP”) License
Any person who carries on, or intends to carry on, a trust or company service business in Hong Kong must obtain a TCSP licence. Licensing and ongoing supervision are administered under the AMLO regime, and applicants are assessed against “fit-and-proper” criteria and AML/CFT readiness.
How Royal Global Compliance Consulting Helps
We provide end-to-end, regulator-ready support so your submission is coherent, defensible, and inspection-ready.
- Pre-application scoping
Clarify service scope (e.g., company formation, provision of registered office, nominee/trustee services), ownership/control structure, premises readiness, and resourcing. - Regulatory mapping & readiness
Map your model to AMLO requirements (fit-and-proper standards, CDD/EDD, ongoing monitoring, sanctions/PEP screening, record-keeping, STR handling, training, and independent review). - Evidence-based documentation
Build a consistent application pack with aligned narratives across forms, declarations, corporate documents, policies, and premises evidence—complete with version control and audit trail. - Proactive liaison
Coordinate responses to Registry requisitions; manage clarifications on controllers/beneficial owners, premises, and AML/CFT controls. - Decision & post-licensing mobilisation
Implement any licence conditions and launch your compliance calendar, registers, training plan, and monitoring cadence.
Core Application Documents We Assemble
- Application forms for the applicant and prescribed supporting documents.
- Ownership/management filings for each corporate partner, director and ultimate/beneficial owner (where applicable), with identification and declarations.
- Premises documentation for each operating site:
- Stamped tenancy agreement or ownership record, and
- Floor plan identifying the area used for TCSP operations.
- Corporate documents (e.g., constitutional documents, business registration, organisation chart).
- Written confirmations of compliance with AMLO/Guideline requirements, together with the prescribed application fees (we prepare the confirmations and fee schedule for filing).
AML/CFT Framework Build-Out (Included)
To evidence readiness under AMLO, we tailor a fit-for-purpose AML/CFT framework, typically including:
- Enterprise ML/TF risk assessment (products/services, customers, geography, delivery channels)
- Policies & procedures: CDD/EDD (beneficial ownership), PEP/sanctions screening, ongoing monitoring, trigger events, STR process (JFIU), and record-keeping for at least 5 years
- Operational controls: risk ratings, alerts/exceptions, dual control, periodic reviews, data protection/privacy
- Training & competency: induction and annual refreshers; role-specific modules with attendance logs
- Independent review/testing plan and registers/templates (CDD files, STR log, exceptions, training, policy versions)
Application Pathway (At a Glance)
- Intake & gap analysis – confirm scope, controllers/UBOs, premises, documents, and timeline.
- Compilation & filing – lodge complete forms, written confirmations, and fees with supporting exhibits.
- Regulatory vetting – respond to requisitions; provide clarifications and evidence.
- Decision & conditions – address any licence conditions and formalities.
- Post-licensing – operationalise monitoring, registers, training and periodic attestations.
Typical Deliverables
- Complete application pack (forms, declarations, exhibits)
- Written confirmations of compliance and fee schedule ready for submission
- Tailored AML/CFT policy suite and risk assessment
- Redline + clean versions with an issue/action log
- Post-licensing compliance calendar and register set
Why Engage Royal Global
- Legal-grade drafting that withstands regulatory scrutiny
- Practical, proportionate controls aligned to your service scope and risk profile
- Single accountable team coordinating the process through to approval
