ECSH52300 - Trust or Company Service Providers (TCSPs) providing Accountancy Service Providers or other supervised sector services

It is not unusual for an TCSP to provide services which would fall within the definition of an ASP. In such cases the business is acting as both a TCSP and an ASP and its registration must reflect this, as must its compliance with the MLR 2017.

Where a TCSP is also conducting relevant ASP activity, you should also refer to section ECSH52500 Accountancy service providers (ASPs).

A TCSP who also acts as an ASP, will usually provide a registered office address service. This TCSP service enables an ASP to receive their customers’ formal communications from HMRC and/or Companies House, and assist the ASP with making sure their customers meet obligations to file confirmation statements, tax returns and so on. Generally, the TCSP will not receive commercial correspondence on behalf of their customers’ trading activities.

An ASP might also act as TCSP by forming firms for an existing customer or providing a standalone company formation service to new customers wishing to set up or incorporate their business.

There are TCSP businesses that conduct relevant activity under MLR 2017 other than (and/or in addition to) that of an ASP. This includes some Estate Agency Businesses (EABs) and a small number of Money Service Businesses (MSBs) where their business model includes TCSP activity.

In all cases, the business's registration for AML supervision must describe of the relevant activity the business conducts and it must adhere to all of its obligations under the MLR 2017.

(This content has been withheld because of exemptions in the Freedom of Information Act 2000)

General money laundering, terrorist financing and proliferation financing risks for TCSPs can be found at ECSH52125 General risks in the Trust or Company Service Provider (TCSP) sector and general risks for ASPs can be found at ECSH52625 General risks in the Accountancy Service Provider (ASP) sector. At a compliance visit, TCSPs providing ASP services should be expected to provide an explanation for any departure from published guidance.

You should also refer to the section of the handbook relevant to: