The Hong Kong TCSP Licence in 2026: Who Must Hold One, the Fit and Proper Test, the CDD Duties and What Enforcement Actually Costs

A trust or company service provider (TCSP) licence is mandatory in Hong Kong for anyone who, by way of business, provides other persons with a registered office, director or secretary services, a nominee shareholder or a trustee. The regime sits in Part 5A of the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615) and is administered by the Companies Registry. A licence runs for three years; at the end of June 2026 there were 7,412 licensees.

Important. Carrying on a trust or company service business without a licence is a criminal offence under section 53F of Cap. 615: a fine at level 6 (HK$100,000) and six months’ imprisonment, with the magistrate additionally empowered to disqualify the person from holding a licence for a specified period. And the licence is required even where you never act as secretary: providing a registered office or a correspondence address is itself within the definition of the service.

The second point that reframes the risk assessment: a TCSP licensee cannot be prosecuted for breaching the Schedule 2 customer due diligence and record-keeping requirements. The criminal offences in section 5(5)–(8) of Cap. 615 are addressed to financial institutions, and a TCSP licensee is a DNFBP. Its exposure for a Schedule 2 breach is disciplinary, under section 53Z: public reprimand, a remedial order, and a pecuniary penalty of up to HK$500,000.

Key parameters as at September 2026

Parameter	Position	Source
Regulator	the Registrar of Companies (Companies Registry)	Cap. 615, Part 5A
Provision creating the regime	Part 5A added by Ordinance 4 of 2018, s. 18	Cap. 615
Co­mmence­ment of the regime	1 March 2018	editorial note to s. 53ZQ
Definition of the service	four activities in Schedule 1, Part 1	Cap. 615, Sch. 1
Permitted applicant forms	sole proprietor, partnership, corporation	s. 53G(1)
Licence validity	3 years (or shorter at the Registrar’s discretion)	s. 53O
Renewal application	no later than 60 days before expiry	s. 53K(2)(a)
Grant fee	HK$3,440 plus HK$975 for each person taking the test	Sch. 3A, item 3
Renewal fee	HK$2,910 plus HK$975 for each person	Sch. 3A, item 4
Approval of a new participant	HK$1,140 per person	Sch. 3A, items 5–7
Operating without a licence	fine at level 6 (HK$100,000) and 6 months’ imprisonment	s. 53F(2)
New ultimate owner, partner or director without approval	fine at level 5 (HK$50,000) and 6 months’ imprisonment	ss. 53S(6), 53T(6), 53U(6)
No­tifi­cation of changes in particulars	within 1 month; breach is a level 5 fine	s. 53W
Maximum pecuniary penalty	HK$500,000	s. 53Z(3)(c)
Daily penalty for ignoring a remedial order	up to HK$10,000 a day	s. 53Z(4)
Occasional transaction threshold for CDD	HK$120,000	Sch. 2, s. 3(1)(b)
Record retention	at least 5 years	Sch. 2, s. 20(2)–(3)
Time to complete customer veri­fica­tion	30 working days; suspend at 30; terminate at 120 working days	Guideline, para 4.7.3
Challenging a Registrar decision	21 days to the AMLCTF Review Tribunal; the decision does not take effect before that period expires	ss. 59(1), 75
Licensees at end-June 2026	7,412; 333 new licences granted in the first half of 2026	Companies Registry, 17.07.2026
Published disciplinary cases	20, from 2 September 2024 to 30 June 2026	Companies Registry
Published pro­secutio­ns	12, from 25 November 2021 to 20 November 2025	Companies Registry

The legal framework: one ordinance, three guidelines and one repealed Division

The whole TCSP licensing regime sits in Part 5A of the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615) — sections 53A to 53ZQ — together with Schedules 1, 2 and 3A. Hong Kong has no separate TCSP statute.

The structure of the regulation

Level	Instrument	What it governs	Status
Statute	Cap. 615, Part 5A (ss. 53A–53ZQ)	licensing, approvals, noti­fica­tions, disciplinary powers	in force; consolidated text version date 15 May 2026
Statute	Cap. 615, Schedule 1, Part 1	the definitions of “trust or company service” and “trust or company service business”	added by Ordinance 4 of 2018, s. 25
Statute	Cap. 615, Schedule 2	customer due diligence and reco­rd-kee­ping requirements	replaced by Ordinance 4 of 2018, s. 26; amended by 15 of 2022, s. 33
Statute	Cap. 615, Schedule 3A	fees under Part 5A	added by Ordinance 4 of 2018, s. 27
Guideline	Guideline on Licensing of Trust or Company Service Providers, May 2025edition	the grant and renewal procedure and the fit and proper test	current
Guideline	Guideline on Anti-Money Laundering and Counte­r-Fi­nancing of Terrorism (For TCSP Licensees), March 2025	how Schedule 2 is applied in practice	published under s. 7 of Cap. 615; gazetted at G.N. 7288 of 6 December 2024
Guideline	Guideline on Imposition of Pecuniary Penalty, March 2018	how the Registrar sets the amount of a penalty	published under s. 53ZB; gazetted at G.N. 709 of 9 February 2018

The amendment chain

Part 5A was inserted by the Anti-Money Laundering and Counter-Terrorist Financing (Amendment) Ordinance 4 of 2018, section 18, and came into operation on 1 March 2018. The commencement date appears not in the section text but in the editorial note to section 53ZQ — a detail most write-ups omit.

Part 5A itself has been amended twice since 2018, both times by the same Ordinance 15 of 2022. The whole of Part 5A carries exactly two editorial amendment notes and no others:

Note in the consolidated text	What it touches	Provision of the amending Ordinance
“(Amended 15 of 2022 s. 25)”	section 53A, Inte­rpre­tation of Part 5A — the definitions, including ultimate owner	s. 25 of Ordinance 15 of 2022
“(Repealed 15 of 2022 s. 26)”	the whole of Division 7 (sections 53ZH to 53ZK)	s. 26 of Ordinance 15 of 2022

The repealed Division 7 carried its own mechanism for reviewing the Registrar’s decisions; since its repeal, review lies wholly with the AMLCTF Review Tribunal established by section 55. Ordinance 15 of 2022 is the same instrument that inserted Part 5B on virtual asset service providers into Cap. 615. The consolidated text records that section 53A was amended but not what the amendment did; in practice this means the Part 5A definitions must be read in their current form rather than as enacted in 2018.

Schedule 3A, which sets the fees, has never been amended since 2018. That is a checkable statement: beneath the Schedule 3A table the consolidated text carries the single note “(Schedule 3A added 4 of 2018 s. 27)” and no amendment note at all. By contrast the neighbouring Schedule 3, which prices money service operator applications, carries “(Amended L.N. 22 of 2026)”. Section 53ZL nevertheless lets the Registrar of Companies amend Schedule 3A by notice in the Gazette — the tariff can move without an amending Ordinance.

Three instruments of 2025–2026 that leave the TCSP regime untouched

Cap. 615 was amended repeatedly in 2025 and 2026, and none of those amendments reached Part 5A. This is worth checking before relying on any reference to “the recent AMLO amendments”:

•          Ordinance 17 of 2025 (stablecoins) added “stablecoin licensee” to the Schedule 1 list of financial institutions;

•          Ordinance 14 of 2025 (company re-domiciliation) adjusted definitions relating to virtual asset service providers and dealers in precious metals and stones;

•          L.N. 22 of 2026 amended Schedule 3 — the money service operator fees.

None of the three carries an amendment to sections 53A to 53ZQ.

The wider set of corporate obligations a Hong Kong company carries — the reason a licensed provider is engaged in the first place — is covered separately in mandatory annual compliance for Hong Kong companies.

What the law treats as a trust or company service

“Trust or company service” is defined in section 1 of Part 1 of Schedule 1 to Cap. 615 as the provision, in Hong Kong, by a person, by way of business, of one or more of four services to other persons. The definition is closed: a service that is not on the list needs no licence.

The four activities

First — forming corporations or other legal persons. The statutory words are exactly that.

Second — acting, or arranging for another person to act, as a director or a secretary of a corporation, as a partner of a partnership, or in a similar position in relation to other legal persons. The phrase “or arranging for another person to act” pulls in the intermediary who never becomes a director himself but sources and supplies one.

Third — providing a registered office, business address, correspondence or administrative address for a corporation, a partnership or any other legal person or legal arrangement.

Fourth — acting, or arranging for another person to act, as a trustee of an express trust or a similar legal arrangement, or as a nominee shareholder for a person other than a corporation whose securities are listed on a recognized stock market.

“Trust or company service business” is defined separately and very briefly: the business of providing a trust or company service. Both definitions were added by Ordinance 4 of 2018, section 25.

The three limiting words inside the definition

The first limit is “in Hong Kong”. The service must be provided in Hong Kong. The definition says nothing about where the serviced company is incorporated: a Hong Kong provider servicing offshore structures is inside the perimeter.

The second limit is “by way of business”. A one-off act outside commerce falls outside; the distinguishing factors are set out in the next section.

The third limit is “to other persons”. The service must be supplied to someone other than the provider itself. That wording is what carries the analysis of servicing companies within one’s own group.

What the definition excludes

An exclusion is built into the fourth limb: holding shares as nominee for a corporation whose securities are listed on a recognized stock market requires no licence. It is the only substantive carve-out written into the definition itself.

Leasing office or business premises is outside the definition. The Companies Registry confirms the point expressly: a landlord letting premises to clients need not hold a TCSP licence.

Preparing companies’ annual returns is outside the definition. Where that is the only service provided, no licence is required.

One boundary is worth drawing clearly, because the two regimes live in the same ordinance: Part 5B of Cap. 615 governs virtual asset service providers, and that is a separate licence from a different regulator — the Securities and Futures Commission. That regime is covered separately in licensing virtual asset service providers in Hong Kong.

Who needs a licence and who does not: the situations that decide it

A licence is required by anyone who supplies at least one of the four services by way of business and does not fall within the section 53B exemptions. The question is almost never about the list of services; it is about whether the activity is carried on “by way of business”.

The four indicators of “by way of business”

The Companies Registry states expressly that this is a question of fact to be answered on all the circumstances, and identifies four relevant indicators: whether the person undertakes one or more of the activities of a TCSP; whether the person advertises or publicises the activity or receives referrals from other companies; whether the person aims to make a profit; and whether the activity is carried out with reasonable or recognizable continuity.

No single indicator decides the question — they are weighed together.

Situations that do require a licence

Situation	Licence required	Basis
A business centre supplies a registered office and corre­spo­ndence address to third-party companies	Yes	third limb of the definition
A firm provides a registered office but never acts as secretary	Yes	third limb of the definition
A provider sources and supplies nominee directors to clients without becoming a director itself	Yes	the words “arranging for another person to act”
A Hong Kong provider services only its clients’ offshore companies	Yes	the service is provided in Hong Kong
A provider acts as trustee of express trusts for clients	Yes	fourth limb of the definition

Situations that do not

Situation	Licence required	Basis
A landlord lets office or business premises	No	leasing is outside the definition
A person prepares only clients’ annual returns	No	preparing annual returns is outside the definition
A person is company secretary of a parent’s company and provides secretarial services to no one else	No	no carrying on of a business
A person acts once as nominee shareholder for a parent with no commercial gain	No	a one-off appointment without commercial gain
Holding shares as nominee for a listed corporation	No	the carve-out inside the fourth limb

Servicing companies within your own group

The Companies Registry offers a rule of thumb built on three cumulative conditions: no licence is required where the person is a member of a group of companies; receives no service fee for the company services provided to other group members; and provides those services only to group members and to no one else.

The regulator says expressly that this is an example rather than an exhaustive rule: in other situations where a member of a corporate group provides company services solely to other group members, that would not normally be regarded as providing the services by way of business and would not normally require a licence.

The practical point is that the fee condition is the fragile one. An intra-group recharge for corporate services moves the position out of the safe zone and into one where the answer turns on the balance of indicators rather than following automatically.

Where the structure is being built together with the company itself, it helps to know in advance what obligations a Hong Kong entity carries: Hong Kong company registration in 2026.

The section 53B exemptions: who may provide the same services without a licence

Section 53B lists six categories to which Part 5A does not apply: the Government; an authorized institution; a licensed corporation that operates a trust or company service business ancillary to the corporation’s principal business; an accounting professional; a legal professional; and a class or description of persons prescribed by regulation.

Section 53B(2) empowers the Secretary for Financial Services and the Treasury to prescribe by regulation a class or description of persons to whom Part 5A does not apply.

The trap in the licensed corporation wording

The exemption for a licensed corporation — a holder of a Securities and Futures Commission licence — is not unconditional. It applies only where the trust or company service business is ancillary to the corporation’s principal business.

A licensed corporation for which corporate services are a revenue line in their own right, rather than something ancillary to its licensed activity, is not taken out of the regime. The words “ancillary to the corporation’s principal business” are a condition, not a description.

Accounting professionals: six configurations with different answers

The Companies Registry sets this category out in the most detail, because it is where the analysis most often goes wrong.

Configuration	Licence required	Who supervises
A certified public accountant carrying on business as a sole proprietor	No	the AFRC; the Schedule 2 requirements still apply
A CPA firm practising accountancy in partnership	No	the AFRC; the Schedule 2 requirements still apply
A partnership that is not a CPA firm but in which allpartners are accounting professionals	No	the AFRC; the Schedule 2 requirements still apply
A partnership in which at least one partner is not an accounting professional	Yes	the Registrar, but no fit and proper test is run on the accountant partners
A corporate practice within the meaning of Cap. 588	No	the AFRC; the Schedule 2 requirements still apply
Any other corporation	Yes	the Registrar, but no test is run on the accountant directors

Note the asymmetry: exemption from the licence and exemption from the test are two different things. A partnership with a single non-accountant partner must be licensed, but only the partners who are not accounting professionals are put through the test.

Exemption from the licence is not exemption from the CDD and record-keeping duties. An accounting professional and a legal professional remain DNFBPs under Schedule 1 and must comply with Schedule 2 — supervision simply sits with a different body.

A limit on scope that applies to accountants and lawyers but not to TCSPs

Section 5A(3) confines the Schedule 2 requirements, for accounting and legal professionals, to seven kinds of transaction prepared or carried out for a client: buying or selling real estate; managing client money, securities or other assets; management of bank, savings or securities accounts; organisation of contributions for the creation, operation or management of corporations; the creation, operation or management of legal persons or legal arrangements; buying or selling business entities; and any service within the definition of “trust or company service”.

No such limit applies to a TCSP licensee: Schedule 2 governs the whole of its trust or company service business, with no transaction-by-transaction filter. That makes the compliance burden on a TCSP licensee objectively wider than on an accountant or a lawyer providing the same services.

Who counts as an ultimate owner, and who takes the test

“Ultimate owner” is defined in section 53A and works differently for a sole proprietor, a partnership and a corporation. For a partnership and a corporation the ownership or control threshold is more than 25%.

The three limbs of the definition

In relation to an individual carrying on business as a sole proprietor, the ultimate owner is another individual who ultimately owns or controls that person’s trust or company service business; or, where the first individual is acting on behalf of another person, that other person.

In relation to a partnership, the ultimate owner is an individual who meets any one of four tests: is entitled, directly or indirectly, to more than a 25% share of the capital or profits; controls, directly or indirectly, more than a 25% share of the capital or profits; is, directly or indirectly, entitled to exercise or control the exercise of more than 25% of the voting rights; or exercises ultimate control over the management of the partnership.

In relation to a corporation, the ultimate owner is an individual who owns or controls, directly or indirectly — including through a trust or bearer share holding — more than 25% of the issued share capital; is, directly or indirectly, entitled to exercise or control the exercise of more than 25% of the voting rights at general meetings; or exercises ultimate control over the management of the corporation.

An ultimate owner is always a natural person, save in the sole-proprietor case where the individual acts on behalf of another person. The ownership chain is followed through to the individual at the end of it.

Exactly who takes the fit and proper test

Applicant’s form	Who is tested	What is filed
Sole proprietor	the individual and each ultimate owner	Form TCSP4 for an individual, TCSP5 for a corporation
Partnership	each partner and each ultimate owner	Form TCSP4 or TCSP5 for each
Corporation	each director and each ultimate owner	Form TCSP4 or TCSP5 for each
Approval of a new participant	the person proposed to become an ultimate owner, partner or director	Form TCSP4 or TCSP5 with Form TCSP3

Note the asymmetry in the wording of section 53H: a sole proprietor and partners must be fit and proper “to carry on” a trust or company service business, while a corporation’s directors and any ultimate owner must be fit and proper “to be associated with” such a business. Section 53H contains no requirement that the applicant corporation itself be found fit and proper: what is tested are its directors and its ultimate owners.

Residence is irrelevant. The Companies Registry confirms expressly that an ultimate owner resident outside Hong Kong takes the test unless exempt under section 53B.

An alternate director takes the test on the same footing as a full director — a separately confirmed regulator position, and an easy one to miss when planning a board.

Exempt from the test are: certified public accountants, solicitors and foreign lawyers among individuals; corporate practices of accountants, authorized institutions and licensed corporations among bodies corporate. In place of Form TCSP4 or TCSP5, a copy of the document proving membership of the exempt category is filed.

The TCSP concept of an ultimate owner is not the same as the significant controller concept in Hong Kong company law — two different registers, with different thresholds and different consequences; the second is covered separately in the Significant Controllers Register in Hong Kong.

The fit and proper test: what the Registrar actually examines

Section 53I requires the Registrar, in deciding whether a person is fit and proper, to have regard to five categories of matter — and, in addition, to any other matter the Registrar considers relevant. The list is not exhaustive.

The five statutory heads

First, conviction of a listed Hong Kong offence: an offence under sections 5(5)–(8), 10(1), (3), (5)–(8), 13(1), (3), (5)–(8), 17(9), 20(1), 61(2) or 66(3) of Cap. 615 itself; an offence under section 14 of the United Nations (Anti-Terrorism Measures) Ordinance (Cap. 575); an offence under sections 25(1), 25A(5) or (7) of, or specified in Schedule 1 to, the Drug Trafficking (Recovery of Proceeds) Ordinance (Cap. 405); or an offence under sections 25(1), 25A(5) or (7) of, or specified in Schedule 1 or 2 to, the Organized and Serious Crimes Ordinance (Cap. 455).

Second, a conviction outside Hong Kong for an act that would have constituted one of those offences had it been done in Hong Kong; for an offence relating to money laundering or terrorist financing; or for an offence for which it was necessary to find that the person had acted fraudulently, corruptly or dishonestly.

Third, failure to comply with a requirement imposed under Cap. 615 or under a regulation made under section 53ZM.

Fourth, for an individual: whether he or she is an undischarged bankrupt or the subject of bankruptcy proceedings under Cap. 6.

Fifth, for a corporation: whether it is in liquidation, subject to a winding up order, or has a receiver appointed in relation to it.

What the Registrar’s practice adds

The Companies Registry states expressly that it will request additional information and documentary evidence whenever necessary, and that in some cases it will invite the person to attend an interview at its office to answer questions about the information provided. That matters: the test is not a form-filling exercise.

The words “in addition to any other matter that the Registrar considers relevant” mean that a clean criminal record does not guarantee a pass. Regulatory history in other jurisdictions, a refusal by another authority, the character of previous business activity — all can be weighed, none of it named in section 53I.

The same test is applied three times

First, on the grant of a licence (section 53H).

Second, on renewal: section 53K(3) applies sections 53H(1), (2), (3) and 53I to a renewal application as they apply to an application for a grant. Renewal is not a formality; the population of tested persons is reassessed from scratch.

Third, on approval of a new ultimate owner, partner or director: subsection (3) of each of sections 53S, 53T and 53U requires the Registrar to have regard to the same section 53I matters.

What follows from a negative result

If the Registrar is not satisfied, the Registrar may refuse to grant or renew the licence, or refuse to approve the new participant.

If the Registrar ceases to be satisfied about an existing licensee, section 53Q applies: the licence may be revoked, or suspended — for a period specified by the Registrar or until the occurrence of an event specified by the Registrar.

A structural point worth holding on to: section 53Q lists only grounds tied to loss of fitness. A breach of the Schedule 2 requirements is not, of itself, a ground for revocation under section 53Q — that is handled by the separate disciplinary machinery of section 53Z.

Every one of these decisions comes with a written notice stating the reasons and stating the right to apply to the Review Tribunal.

What a TCSP licence costs and how it is obtained

The grant fee is HK$3,440 plus HK$975 for each person who takes the fit and proper test. The tariff sits in Schedule 3A to Cap. 615 and has not changed since 2018.

The complete Schedule 3A tariff

Item	Service	Fee
1	Certifying a copy of an entry in, or extract from, the register	HK$260 per copy
2	Providing a certificate under section 53E(1)(b)	HK$385 per copy
3	Application for the grant of a licence	HK$3,440 plus HK$975 for each person taking the test
4	Application for the renewal of a licence	HK$2,910 plus HK$975 for each person taking the test
5	Approval for a person to become an ultimate owner of a licensee	HK$1,140 per person
6	Approval for a person to become a partner of a licensee	HK$1,140 per person
7	Approval for a person to become a director of a licensee	HK$1,140 per person

The fee is charged per person, not per company, and that is the main reason quoted and actual costs diverge. A corporation with two directors and one ultimate owner, none of them exempt, pays HK$3,440 plus three times HK$975 on grant — HK$6,365 in total. Renewing the same structure costs HK$2,910 plus HK$2,925 — HK$5,835.

None of the three fees is refundable. The May 2025 guideline repeats this at paragraphs 5.2, 6.3 and 8.3 for grant, renewal and approval respectively; for cancellation on cessation of business the same follows from section 53X(3). A refusal by the Registrar does not return the fee.

Who may apply

Section 53G(1) admits three applicant forms: an individual carrying on business as a sole proprietor; a partnership; a corporation. The statute knows no others.

Section 53G(2) requires the application to be made in the form and way specified by the Registrar and to be accompanied by a copy of a valid business registration certificate and the Schedule 3A fee.

The set of forms

Form TCSP1 is the application for a grant. Form TCSP2 is the renewal application. Form TCSP3 is the application to approve a person as an ultimate owner, partner or director.

Form TCSP1 must be delivered together with two supplementary sheets — Form TCSP1-SIS and Form TCSP1-SIS2A. The Companies Registry states this in the title of the form itself; an application without them is incomplete. Notifications go on separate forms: Form TCSP6 for a change in previously delivered particulars under section 53W, and Form TCSP7 for cessation of business under section 53X.

Each is accompanied by a statement as regards the fit and proper criteria: Form TCSP4 for an individual, Form TCSP5 for a corporation. For a person within an exempt category, a copy of the document proving membership of that category is filed instead of Form TCSP4 or TCSP5.

Licence conditions and the form of the licence

Section 53J(1): on granting a licence the Registrar may impose any condition the Registrar considers appropriate.The statute places no limit on the content of a condition.

A condition takes effect when the licensee receives the notice, or at the time specified in the notice, whichever is later (section 53J(4)).

Section 53M lets the Registrar amend the conditions of a live licence, and section 53L lets conditions be imposed or amended on renewal. Each of those decisions is reviewable by the Review Tribunal.

Section 53N(2): the licence must state the period for which it is valid and the business address of the sole proprietor, the partnership or the corporation, as the case may be.

How long it lasts

A licence granted under section 53G is valid for three years from the date of grant — or for a shorter period determined by the Registrar, if the Registrar considers it appropriate in a particular case (section 53O). The same construction governs a renewed licence: three years from renewal, or a shorter period at the Registrar’s discretion.

The Companies Registry’s May 2025 guideline puts it as “normally, the validity period of a licence granted will be 3 years” — three years is the norm, not a guarantee.

Renewal, and the events that end a licence automatically

A renewal application must be made at least 60 days before the licence is due to expire. Section 53K(2) makes that mandatory, not advisory.

How renewal works

The application is made in the form and way specified by the Registrar and is accompanied by the Schedule 3A fee — HK$2,910 plus HK$975 for each person taking the test.

Section 53K(3) applies sections 53H(1), (2), (3) and 53I in full to a renewal: the fit and proper test is run again on every serving partner, director and ultimate owner.

Section 53K(4) removes the gap risk: if the licence expires before the application is determined — and provided the application is not withdrawn and the licence is neither revoked nor suspended — the licence remains in force until it is renewed or, if it is not renewed, until the refusal takes effect as a specified decision under section 75.

Section 53K(7): a renewal takes effect on the day following the expiry of the licence or, where subsection (4) applies, on the day following the day the licence would otherwise have expired. Delay in processing therefore does not shorten the three-year term.

The practical point is that filing 60 days out protects against interruption, not against refusal. A later application is not provided for by section 53K, and the subsection (4) protection does not reach it — when the licence expires, the business becomes unlicensed, with everything section 53F carries.

Four events that end a licence without any decision

Section 53P: a licence ceases to be valid on the death of a sole proprietor; on the dissolution of a partnership; and on the commencement of the winding up of a corporation.

No decision by the Registrar and no notice is needed — the cessation follows from the event itself. For a partnership this means that a change in composition amounting to dissolution at general law can extinguish the licence.

Ending the business on the licensee’s own initiative

Section 53X(1): a licensee intending to cease carrying on its trust or company service business must notify the Registrar of that intention and of the intended date of cessation, before that date.

Section 53X(2): the Registrar cancels the licence with effect from the intended cessation date, as soon as reasonably practicable after receiving the notification.

Section 53X(3): a fee paid for the grant or renewal of a licence is not refundable on cancellation.

Section 53X(4): failing without reasonable excuse to give the notification is an offence carrying a fine at level 5 — up to HK$50,000.

Note the asymmetry: the notification is due “before the intended date of cessation”, and the statute sets no number of days. A notice given on the day of actual cessation formally satisfies the requirement; a notice given afterwards does not.

Winding down the Hong Kong company itself runs on different rules and a different authority, covered separately in closing a Hong Kong company.

Approvals and notifications: where licensees most often slip

A change of ultimate owner, partner or director of a licensee requires the Registrar’s prior written approval. Not notification after the event — prior approval.

The three prior-approval prohibitions

Section 53S(1): a person must not become an ultimate owner of a licensee unless the Registrar gives approval in writing.

Section 53T(1): a person must not become a partner of a licensee that is a partnership without the Registrar’s written approval.

Section 53U(1): a person must not become a director of a licensee that is a corporation without the Registrar’s written approval.

The application is made by the licensee, not by the individual (subsection (2) of each of the three sections).Approval may be given only if the Registrar is satisfied the person is fit and proper, having regard to the section 53I matters.

The sanction is identical in all three cases: contravening without reasonable excuse is an offence carrying a fine at level 5 (HK$50,000) and six months’ imprisonment. The person bound here is the one who becomes the participant, not only the licensee.

The practical trap is that the statute prohibits a person from “becoming” an ultimate owner, partner or director before approval. A share sale or a board appointment completed before approval creates the offence at the moment it is completed; obtaining approval afterwards does not undo it. The statute preserves a “reasonable excuse” defence, but a later approval by the Registrar is not in itself such an excuse.

Notification of changes in particulars

Section 53W(1): where there is a change in the particulars previously provided to the Registrar in connection with an application for the grant or renewal of a licence, the licensee must notify the Registrar of the change within one month beginning on the date on which the change takes place.

Section 53W(2) widens the reach: particulars previously provided include particulars notified under subsection (1) itself. A change once notified therefore becomes, in turn, the baseline for the next notification duty.

Section 53W(4): failure to comply without reasonable excuse is an offence carrying a fine at level 5.

This duty is the subject of one of the published disciplinary cases: on 15 January 2025 a licensee received a public reprimand and a HK$5,000 pecuniary penalty for failing to notify the Registrar of changes within the required time.

The deadlines and sanctions in one table

Action	Deadline	Sanction for breach	Provision
Approval of a new ultimate owner	before the person becomes one	level 5 fine and 6 months’ imprisonment	s. 53S
Approval of a new partner	before the person becomes one	level 5 fine and 6 months’ imprisonment	s. 53T
Approval of a new director	before the person becomes one	level 5 fine and 6 months’ imprisonment	s. 53U
Notification of a change in particulars	1 month from the date of change	level 5 fine	s. 53W
Notification of cessation of business	before the intended cessation date	level 5 fine	s. 53X
Renewal application	at least 60 days before expiry	loss of the s. 53K(4) protection	s. 53K(2)(a)

Every row but the last is additionally a ground for disciplinary proceedings under section 53Z(2)(b) — so a single failure can attract both a prosecution and a disciplinary sanction.

The Schedule 2 duties: customer due diligence and record-keeping

Schedule 2 to Cap. 615 reaches a TCSP licensee through section 5A and covers the whole of its trust or company service business — without the transaction-by-transaction filter that applies to accountants and lawyers.

The four customer due diligence measures

Section 2 of Schedule 2 defines the CDD measures as identifying the customer and verifying the customer’s identity using reliable and independent source documents, data or information; identifying the beneficial owner and verifying that person’s identity so as to understand the ownership and control structure; obtaining information on the purpose and intended nature of the business relationship; and identifying any person purporting to act on behalf of the customer and verifying that person’s authority.

When CDD is mandatory

Section 3(1) of Schedule 2 names four circumstances: before establishing a business relationship; before carrying out an occasional transaction for the customer involving an amount equal to or above HK$120,000 or the equivalent in another currency, whether in a single operation or in several that appear to be linked; when the licensee suspects that the customer or the customer’s account is involved in money laundering or terrorist financing; and when the licensee doubts the veracity or adequacy of information previously obtained about the customer.

The HK$8,000 thresholds for wire transfers and virtual asset transfers in sections 3(1A) and 3(1B) do not apply to DNFBPs — they are addressed to financial institutions and licensed VAS providers. Conflating those thresholds is a common error in secondary write-ups.

Deferred verification and its outer limit

Section 3(2) permits identity verification of the customer and any beneficial owner after the business relationship is established, on two conditions: that this is necessary not to interrupt the normal conduct of business, and that any money laundering or terrorist financing risk arising from the delay is effectively managed.

Section 3(3) requires that verification to be completed as soon as reasonably practicable after the relationship is established.

Section 3(4) sets out what follows if the requirements cannot be met: the licensee must not establish the business relationship or carry out the occasional transaction, and where the relationship already exists, must terminate it as soon as reasonably practicable.

Ongoing monitoring

Section 5 of Schedule 2 requires the licensee to monitor the relationship continuously on three fronts: reviewing from time to time the documents, data and information obtained for CDD purposes to ensure they remain up to date and relevant; conducting appropriate scrutiny of transactions carried out for the customer to ensure consistency with the licensee’s knowledge of the customer, its business, risk profile and source of funds; and identifying transactions that are complex, unusually large, of an unusual pattern or without apparent economic or lawful purpose, examining their background and purposes and setting out the findings in writing.

The ongoing monitoring duties reach pre-existing customers as well as new ones. Schedule 2 defines a pre-existing customer, for a DNFBP other than a Category B PMS registrant, as one with whom the business relationship was established before 1 March 2018 — the date Part 5A came into force. A legacy client book is not outside the monitoring duty.

Internal procedures

Section 19(1) of Schedule 2 requires effective procedures for determining whether a customer or a beneficial owner is a politically exposed person.

Section 19(3) requires, for each kind of customer, business relationship, product and transaction, effective procedures not inconsistent with the Ordinance for carrying out the duties under sections 3, 4, 5, 9, 10 and 15 of Schedule 2.

Retention periods

What is kept	Period	Provision
Documents and data for each transaction carried out	at least 5 years from completion of the transaction, whether or not the relationship ends within that period	s. 20(2)
Customer and beneficial owner ide­ntifi­cation documents, account files and business corre­spo­ndence	throughout the relationship and at least 5 yearsfrom the date it ends	s. 20(3)
The same, for an occasional transaction	at least 5 years from completion of the transaction	s. 20(3A)
An extended period required in writing	the period specified in the notice	s. 20(4)–(5)

Section 20(4) lets the Registrar require, by notice in writing, that records relating to a specified transaction or customer be kept for longer than the statutory periods, where they are relevant to an ongoing investigation or to any other purpose specified in the notice.

Section 23 of Schedule 2 — the provision licensees fail most often

Section 23 of Schedule 2 requires a financial institution or a DNFBP to take all reasonable measures (a) to ensure that proper safeguards exist to prevent a contravention of any requirement under Part 2 or Part 3 of Schedule 2, and (b) to mitigate money laundering and terrorist financing risks.

The provision is drafted as a second-order obligation: it is breached not because a particular CDD step was performed badly, but because the licensee has no system in place to prevent such a breach at all. That is why it appears in almost every published disciplinary case — nineteen out of twenty. The second most frequent ground is section 19(3), in seventeen of the twenty.

The practical consequence: performing one customer check correctly is not enough — what is required is a documented system that makes correct performance repeatable. The absence of such a system is a breach in its own right, even where no individual customer file is criticised.

The March 2025 guideline: what the regulator expects beyond the statute

The current Guideline on Anti-Money Laundering and Counter-Financing of Terrorism (For Trust or Company Service Provider Licensees) is dated March 2025, is published under section 7 of Cap. 615, was gazetted at G.N. 7288 of 6 December 2024, and runs to 75 pages.

The legal status of a guideline: neither law nor mere advice

Section 7(4): a failure to comply with a provision of a published guideline does not by itself render a person liable to judicial or other proceedings, but in any proceedings under the Ordinance the guideline is admissible in evidence, and if a provision of it appears to the court to be relevant to a question arising, it must be taken into account.

Section 7(5): in considering whether a person has contravened a provision of Schedule 2, the regulator must have regard to the relevant provisions of the published guideline.

Section 7(6): a guideline is not subsidiary legislation.

What this construction means in practice: only Schedule 2 can be contravened, but compliance will be demonstrated through the guideline. Departing from the guideline is permissible, but it demands a justification the licensee must be ready to produce.

Ten chapters

The document runs: overview; the risk-based approach; AML/CFT systems; customer due diligence; ongoing monitoring; terrorist financing, financial sanctions and proliferation financing; suspicious transaction reports, law enforcement requests and crime-related intelligence; record-keeping; staff training; appendix and glossary.

The governance architecture

Paragraph 3.5 requires compliance management arrangements to include, at a minimum, oversight by the licensee’s senior management and the appointment of a Compliance Officer (CO) and a Money Laundering Reporting Officer (MLRO).

Paragraph 3.7: senior management must appoint a CO at management level with overall responsibility for the establishment and maintenance of the licensee’s AML/CFT systems.

Paragraph 3.6 puts on the board or its delegated committee, and on senior management, the duty to have a clear understanding of the licensee’s money laundering and terrorist financing risks and to ensure they are adequately managed, with management information on those risks communicated in a timely, complete, understandable and accurate manner.

The verification clock: 30, 30 and 120 working days

Paragraph 4.7.3 gives the “reasonable timeframe” for completing identity verification three concrete markers. The guideline says the timeframe “generally refers to” these periods, so they are markers rather than statutory deadlines; departing from them has to be justified, because under section 7(4) to (6) the guideline must be taken into account.

First: the licensee completes verification no later than 30 working days after the business relationship is established.

Second: if verification remains uncompleted 30 working days after establishment, the licensee suspends the business relationship and refrains from carrying out further transactions, except to return funds to their sources so far as that is possible.

Third: if verification remains uncompleted 120 working days after establishment, the licensee terminates the business relationship.

Note that all three are working days, not calendar days. Getting this wrong moves the outer limit by more than two months.

Paragraph 4.7.2 adds the conditions on which a payment to a third party may be made before verification is complete: no suspicion of money laundering or terrorist financing; the risk assessed as low; the transaction approved by senior management having regard to the nature of the customer’s business; and no match between the recipients’ names and watch lists, including those for terrorist suspects and politically exposed persons.

How often the institutional risk assessment is refreshed

Paragraph 2.9 of the guideline: a TCSP licensee “should conduct its assessment every two years and upon trigger events which are material to the TCSP licensee’s business and risk exposure”. The assessment is documented and approved by senior management.

The Companies Registry publishes separate explanatory notes on the institutional risk assessment, employee screening procedures, the independent audit function, digital identification systems and customer due diligence — standalone documents in the frequently asked questions section of its portal.

Companies Registry inspections, and the criminal exposure for obstructing them

The Companies Registry may enter a licensee’s premises, inspect and copy documents and ask questions about them, and obstructing an inspection is a criminal offence in its own right carrying up to seven years’ imprisonment.

What is subject to inspection

The Companies Registry guideline defines the “business premises” open to inspection as any premises at which the licensee carries on business, including a place of business used for the administration of the licensee’s affairs or business; for the processing of transactions; or for the storage of documents, data or records.

The definition reaches the archive and the server room as readily as the meeting room. A storage location is business premises whether or not clients are ever received there.

A licensee must cooperate with the Registry and give its staff access to business premises for the purpose of ascertaining compliance with the Ordinance, including the inspection and copying of documents and answering enquiries about any record or document relating to the business carried on or any transaction carried out.

The three tiers of criminal exposure under section 10

Tier one — failing, without reasonable excuse, to comply with a requirement imposed under section 9(3), (5), (9) or (10): on conviction on indictment a fine of HK$200,000 and one year’s imprisonment; on summary conviction a fine at level 5 (HK$50,000) and six months.

Tier two — producing a record or document, or giving an answer, that is false or misleading in a material particular, knowing that or being reckless as to whether it is: on conviction on indictment a fine of HK$1,000,000 and two years’ imprisonment; on summary conviction a fine at level 6 (HK$100,000) and six months.

Tier three — the same conduct with intent to defraud, and equally the conduct of a “related person” who with intent to defraud causes or allows the obligated person to fail: on conviction on indictment a fine of HK$1,000,000 and seven years’ imprisonment; on summary conviction a fine at level 6 and six months.

Section 10(11) defines a “related person” as an employee of the obligated person, a person employed to work for them, or a person concerned in their management. The drafting carries liability beyond the company itself, to the licensee’s staff and managers.

Section 10(10) bars double-tracking: no criminal proceedings may be instituted under subsections (1), (3), (5), (6), (7) or (8) in respect of conduct where proceedings were previously instituted for the purposes of section 14(2)(b) in respect of the same conduct and remain pending, or where by reason of that previous institution no further proceedings may lawfully be brought.

Set against the consequences of a Schedule 2 breach

Breach	Nature of liability	Maximum
Carrying on business without a licence (s. 53F)	criminal	HK$100,000 and 6 months’ imprisonment, plus disqua­lifi­cation
False information to the Registrar (s. 53ZN)	criminal	HK$50,000 and 6 months’ imprisonment
Obstructing an inspection (s. 10(1))	criminal	HK$200,000 and 1 year’s imprisonment
False information during an inspection (s. 10(3))	criminal	HK$1,000,000 and 2 years’ imprisonment
The same with intent to defraud (s. 10(5)–(8))	criminal	HK$1,000,000 and 7 years’ imprisonment
Breach of the Schedule 2 requirements	di­scipli­nary only	HK$500,000 pecuniary penalty

The table exposes a marked asymmetry: a TCSP licensee’s heaviest criminal exposure attaches not to the quality of its compliance but to how it conducts itself with the regulator.

The Registrar’s disciplinary powers: three sanctions and a HK$500,000 ceiling

Section 53Z(3) gives the Registrar three disciplinary sanctions: publicly reprimanding the licensee; ordering the licensee to take specified action by a specified date to remedy the contravention; and ordering the licensee to pay a pecuniary penalty not exceeding HK$500,000.

The grounds for disciplinary proceedings

Section 53Z(2) sets out two blocks of grounds.

The first block is a contravention by the licensee of: a requirement set out in Schedule 2 that applies to a DNFBP who is a TCSP licensee; a regulation made under section 53ZM; or a condition of the licence.

The second block is a contravention of section 53S(1), 53T(1), 53U(1), 53W(1) or 53X(1) — changing an ultimate owner, partner or director without approval, failing to notify a change in particulars, or failing to notify cessation of business.

Note that the list is closed. A failing that fits neither block is outside section 53Z disciplinary proceedings altogether.

The daily penalty

Section 53Z(4): where a licensee fails to comply with an order to take remedial action, the Registrar may further order payment of a daily pecuniary penalty not exceeding HK$10,000 for each day on which the failure continues after the compliance date.

The daily penalty is not absorbed into the principal one and accrues independently of the HK$500,000 ceiling that applies to a single penalty.

Payment and publication

Section 53Z(5): a licensee ordered to pay a pecuniary penalty must pay it to the Registrar within 30 days, or within a longer period specified in the notice, after the order takes effect as a specified decision under section 75.

Section 53Z(6): once the decision has taken effect the Registrar may disclose to the public the details of the decision, the reasons for it and any material facts relating to the case. That is the basis on which the Companies Registry maintains its public list of disciplinary cases.

How the amount is set

Section 53ZB requires the Registrar to publish a guideline indicating how the Registrar proposes to exercise the power to impose a pecuniary penalty, to publish it before exercising the power for the first time, and to publish it in the Gazette. The guideline must be had regard to in exercising the power and is not subsidiary legislation.

The Guideline on Imposition of Pecuniary Penalty was issued in March 2018 and gazetted at G.N. 709 of 9 February 2018.

The guideline sets no rates, no bands and no multipliers. The amount is fixed on the whole of the circumstances, grouped under four heads: the nature and seriousness of the contravention — whether it was intentional, its extent, any gains made, whether the failings were systemic, whether crime was facilitated; the licensee’s conduct — attempts at concealment, promptness of reporting, cooperation, remedial steps taken; the compliance history — earlier disciplinary action, earlier contraventions, sanctions imposed by other authorities; and other factors — the size of the business, its financial resources, the likelihood of recurrence, and the particular circumstances of the case.

Directors

Section 53ZD extends the application of the disciplinary powers to directors of corporations. A section 53ZD decision, like a section 53Z decision, is a specified decision and is reviewable by the Review Tribunal.

The distinction that matters: a TCSP licensee is not prosecuted for CDD failures

The criminal offences for breaching the Schedule 2 requirements sit in section 5(5)–(8) of Cap. 615 and are addressed exclusively to financial institutions. A TCSP licensee is not a financial institution — it is a DNFBP, and it bears no criminal liability for a Schedule 2 breach.

How the provision is built

Section 5(5): if a financial institution knowingly contravenes a specified provision, it commits an offence and is liable on conviction on indictment to a fine of HK$1,000,000 and two years’ imprisonment, or on summary conviction to a fine at level 6 and six months.

Section 5(6) raises the exposure to HK$1,000,000 and seven years where the contravention is committed with intent to defraud a relevant authority. Sections 5(7) and 5(8) extend the same offences to employees of a financial institution and to persons concerned in its management.

Section 5(11) lists the “specified provisions” — the particular Schedule 2 provisions whose breach constitutes the offence.

In all four offences the subject named is “a financial institution”. None of them mentions a DNFBP.

The check from the other direction

Schedule 2 reaches a DNFBP not through section 5 but through section 5A, and section 5A creates no offence at all.It does no more than determine which Schedule 2 requirements apply to which type of DNFBP, and define, in subsection (7), an “AML/CTF requirement” as a requirement set out in Part 2, 3 or 4 of Schedule 2.

Nowhere in Cap. 615 is there a formulation of the kind “a DNFBP commits an offence” or “a TCSP licensee commits an offence” in relation to Schedule 2.

The single consequence of a Schedule 2 breach by a TCSP licensee is the one named in section 53Z(2)(a)(i): it is a ground for disciplinary proceedings.

Why this matters in practice

Statements that a TCSP licensee faces a HK$1,000,000 fine and two years’ imprisonment for a CDD failure reproduce a provision that does not apply to it. It is one of the most persistent errors in write-ups of the regime.

The accurate formulation: for a Schedule 2 breach a TCSP licensee risks a public reprimand, a remedial order and a pecuniary penalty of up to HK$500,000 — and, where failings are systemic, a reassessment of its fitness under section 53Q, up to and including revocation of the licence.

The complete list of criminal offences that do apply to a TCSP licensee

Offence	Provision	Sanction
Carrying on a trust or company service business without a licence	s. 53F(1)	level 6 fine and 6 months’ imprisonment; the magistrate may disqualify
Becoming an ultimate owner without approval	s. 53S(6)	level 5 fine and 6 months
Becoming a partner without approval	s. 53T(6)	level 5 fine and 6 months
Becoming a director without approval	s. 53U(6)	level 5 fine and 6 months
Failing to notify a change in particulars	s. 53W(4)	level 5 fine
Failing to notify cessation of business	s. 53X(4)	level 5 fine
False or misleading information to the Registrar	s. 53ZN(3)	level 5 fine and 6 months
Obstructing an inspection, and false information during one	s. 10	from HK$200,000 and 1 year to HK$1,000,000 and 7 years

Section 53ZO sets a special limitation period: despite section 26 of the Magistrates Ordinance (Cap. 227), proceedings for an offence under Part 5A, other than an indictable offence, may be instituted within 12 months after the offence is discovered by, or comes to the notice of, the Registrar.

The monetary value of each level is set not in Cap. 615 but in Schedule 8 to the Criminal Procedure Ordinance (Cap. 221), to which section 113B of that Ordinance refers: level 1 HK$2,000, level 2 HK$5,000, level 3 HK$10,000, level 4 HK$25,000, level 5 HK$50,000, level 6 HK$100,000.

What the record shows: 7,412 licensees, 20 disciplinary cases and 12 convictions

At the end of June 2026 there were 7,412 TCSP licensees in Hong Kong, and the Companies Registry granted 333 new licences during the first half of 2026. The figures were published by the Companies Registry on 17 July 2026. By comparison, there were 7,220 licensees at the end of 2025 and 760 licences were granted across the whole of 2025, so the market continues to add roughly 200 licensees every half-year.

The disciplinary record

The Companies Registry has published 20 disciplinary cases — the first dated 2 September 2024, the most recent 30 June 2026. Before September 2024 there were no published disciplinary cases at all: the first six and a half years of the regime passed without a single published sanction.

Measure	Value
Published disciplinary cases	20
Period covered	2 September 2024 – 30 June 2026
Lowest pecuniary penalty	HK$4,000
Highest pecuniary penalty	HK$32,000
Median penalty	HK$10,000
Aggregate penalties	HK$277,000
Highest penalty as a share of the HK$500,000 ceiling	6.4%

No published penalty has come close to the statutory ceiling: the largest was 6.4% of the maximum.

The standard sanction is a public reprimand combined with a pecuniary penalty; in several cases a remedial order was added.

The pattern of contraventions is stable and repeats from case to case. How often each ground appears across the twenty published cases:

Provision breached	Substance	In how many of the 20 cases
Section 23 of Schedule 2	No proper safeguards against contravention of Parts 2 and 3, and no risk-mi­ti­gation measures	19
Section 19(3) of Schedule 2	No effective procedures for carrying out the duties under ss. 3, 4, 5, 9, 10 and 15	17
Section 2(1) of Schedule 2	Failure to identify the customer or beneficial owner, or to verify a repre­senta­tive’s authority	6
Condition 2 of the licence (s. 53J)	No documented AML/CFT policies, procedures and controls	5
Section 9 of Schedule 2	Special requirements for non-fa­ce-to­-face ide­ntifi­cation not met	5
Section 20 of Schedule 2	Reco­rd-kee­ping requirements breached	3
Section 5(1) of Schedule 2	Inadequate ongoing monitoring of the business relationship	3
Section 53W	Failure to notify the Registrar of changes in time	1

Section 23 of Schedule 2 was breached in nineteen of the twenty cases — effectively the universal ground for a disciplinary case. One case, dated 15 January 2025, concerned a failure to notify the Registrar of changes within the required time. A remedial order was added to the sanction in six of the twenty cases.

The prosecution record

The Companies Registry has published 12 convictions — from 25 November 2021 to 20 November 2025.

Measure	Value
Published prosecutions	12
Period covered	25 November 2021 – 20 November 2025
Persons convicted	12
Counts in total	17 (eleven cases of one count, one case of six)
Lowest fine per count	HK$3,000
Highest fine per count	HK$10,000
Largest total against one defendant	HK$24,000 (six counts at HK$4,000)
Aggregate fines imposed	HK$86,000
Provisions charged	s. 53ZN(1) in all twelve cases; one case additionally under ss. 53S(1) and 53U(1)

Eleven of the twelve cases are purely about providing false or misleading information to the Registrar. The twelfth, dated 14 September 2023, combined six counts — becoming an ultimate owner and a director without approval, and providing false information — at HK$4,000 per count. — HK$24,000 in total against that one defendant.

The section 53ZN(1) offence is not one of strict liability: the person must know that the information is false or misleading, or be reckless as to whether it is. Simple carelessness in completing a form is not the offence — although recklessness is not hard to establish where the statement plainly departs from the facts.

None of the published convictions is under section 53F, for carrying on business without a licence. That is a statement about the published list, not a claim that no such case has ever existed.

How to read this

First: the real sanction for compliance failures is an order of magnitude below the statutory maximum, but it is public. Publication under section 53Z(6) means the licensee’s name, the substance of the failure and the amount all stay in the open — the reputational cost exceeds the financial one.

Second: the likeliest route to a prosecution is not unlicensed operation but an inaccuracy in what was filed with the Registrar. Forms TCSP1 to TCSP5, and the subsequent section 53W notifications, are the principal source of criminal risk in this regime.

Third: the regulator’s activity rose sharply from the autumn of 2024. Twenty disciplinary cases in twenty-two months against none in the preceding six and a half years is a change in supervisory posture, not statistical noise.

When choosing a corporate services provider in Hong Kong, the licence number is worth checking against the public register of licensees, and the company name against the disciplinary and prosecution lists on the same portal. Both lists are open and require no registration.

How a Registrar decision is challenged

A Registrar decision is challenged before the Anti-Money Laundering and Counter-Terrorist Financing Review Tribunal within 21 days after the notice of the decision was sent. Until that period expires the decision does not, as a general rule, take effect.

The nine reviewable decisions

Paragraph (e) of the definition of a specified decision lists the Registrar decisions the Tribunal may review: a refusal to grant a licence under section 53H; the imposition of a licence condition under section 53J; a refusal to renew under section 53K; the amendment or imposition of a condition under section 53L or 53M; revocation or suspension of a licence under section 53Q; a refusal to approve an ultimate owner under section 53S; a refusal to approve a partner under section 53T; a refusal to approve a director under section 53U; and the exercise of a power under section 53Z or 53ZD.

Other acts of the Registrar are outside the list and are not reviewable by the Tribunal.

The deadline and its extension

Section 59(1): a person aggrieved by a specified decision made in relation to them may apply to the Tribunal for a review within the period ending 21 days after the notice informing the person of the decision has been sent.

Time runs from despatch of the notice, not from its receipt. That matters for addressees outside Hong Kong.

Sections 59(2) and (3): the Tribunal may extend the period by order, but only after the applicant and the specified authority have been given a reasonable opportunity to be heard, and only if satisfied that there is good cause.

Section 59(4): an application for review must be in writing and must state its grounds.

The suspensive effect

Section 75 fixes when a specified decision takes effect, and the design gives the applicant protection.

If the person notifies the authority in writing before the 21 days expire that they will not apply for a review, the decision takes effect at that moment. If within the 21 days the person neither gives that notice nor applies for a review, the decision takes effect when the period expires. If the person applies within the 21 days, the decision takes effect when the Tribunal confirms it; where the Tribunal varies or substitutes it, at the time of variation or substitution, subject to their terms; and where the application is withdrawn, at the time of withdrawal.

In practice: a timely review application postpones the coming into effect of a revocation, a suspension or a pecuniary penalty.

The exception is section 75(2): the authority may, if it considers it appropriate in the public interest, specify in the notice a different time at which the decision is to take effect, in which case it takes effect then. The suspensive effect is therefore not absolute.

The Tribunal itself

The Tribunal is established by section 55 and has jurisdiction to review specified decisions and to hear and determine any question or issue arising out of or in connection with a review, in accordance with Part 5 and Schedule 4.

Section 56(1): the Tribunal consists of a chairperson and two other members, appointed by the Secretary.

Section 56(2): the chairperson must be a person eligible for appointment as a judge of the High Court under section 9 of the High Court Ordinance and must not be a public officer — or must be one only by virtue of chairing a board or tribunal established under an Ordinance.

Section 55(3) allows the Secretary to establish additional tribunals where the Secretary considers it appropriate.

Step by step: obtaining a TCSP licence

The order is set by sections 53G to 53O: the business registration certificate first, then the population of tested persons, then the forms and the fee — and only once the licence is granted does the business begin.

Step 1. Test the planned activity against the definition. Match the services against the four limbs of “trust or company service” in section 1 of Part 1 of Schedule 1, and weigh the four business indicators: whether the listed activities are undertaken, whether the activity is advertised or referrals received, whether profit is the aim, and whether it is carried on with reasonable or recognizable continuity.

Step 2. Check the section 53B exemptions. If the applicant, or every partner, is an accounting professional or a legal professional, no licence may be needed at all; if even one partner is not, a licence is required but not everyone takes the test.

Step 3. Choose one of the three permitted forms under section 53G(1): sole proprietor, partnership or corporation. The statute provides no others.

Step 4. Obtain a valid business registration certificate. A copy is mandatory under section 53G(2)(b)(i); without it the application is incomplete.

Step 5. Identify who takes the test. For a sole proprietor, the individual and each ultimate owner; for a partnership, each partner and each ultimate owner; for a corporation, each director and each ultimate owner. Trace the ownership chain to the individuals above the 25% threshold.

Step 6. Calculate the fee. HK$3,440 plus HK$975 for each person not exempt from the test. For a corporation with two directors and one ultimate owner, HK$6,365.

Step 7. File the set: Form TCSP1 together with the mandatory sheets TCSP1-SIS and TCSP1-SIS2A, a Form TCSP4 for each tested individual, a Form TCSP5 for each tested body corporate, proof-of-exemption documents for exempt persons, a copy of the business registration certificate, and the fee.

Step 8. Expect follow-up requests and an interview. The Companies Registry states expressly that it may request further information and invite a tested person to attend its office.

Step 9. Take the licence and read it. It states the validity period and the business address; check separately whether conditions were imposed under section 53J and from when they bite.

Step 10. Build the AML/CFT system before the first client. Appoint a CO at management level and an MLRO; carry out and document the institutional risk assessment; have senior management approve it; put in place the section 19 procedures, including the procedure for identifying politically exposed persons.

Step 11. Set the verification clock. All three periods run from the date the business relationship is established: complete identity verification within 30 working days; suspend the relationship once 30 working days have passed; terminate once 120 working days have passed.

Step 12. Set the retention rules. At least five years for transaction records from completion, and at least five years for customer files from the end of the relationship, with the files kept throughout the relationship itself.

Step 13. Put three dates in the calendar: refreshing the institutional risk assessment every two years; filing the renewal application no later than 60 days before expiry; and the one-month section 53W notification window on any change to previously filed particulars.

Step 14. Before any change of ultimate owner, partner or director, obtain the Registrar’s approval first and complete the transaction or appointment second. Doing it the other way round creates the offence at the moment it is done.

The banking side of a structure serviced by a licensee is covered separately in corporate bank accounts in Hong Kong for non-residents.

Common mistakes and what they cost

The seven mistakes below either recur in the Companies Registry’s published disciplinary and prosecution records or follow directly from the text of the Ordinance. Each carries a measurable price — from HK$2,925 of under-budgeted fee to a level 6 fine and six months’ imprisonment.

Mistake 1. Assuming that supplying an address alone falls outside the regime

Paragraph (c) of the definition of a trust or company service in Part 1 of Schedule 1 makes the provision of a registered office, business address, correspondence address or administrative address for a corporation, a partnership or any other legal person or legal arrangement a service in its own right. Nothing else needs to be supplied alongside it. In answer 6 of the “Licensing requirements” FAQ the Companies Registry states that a business centre providing a registered office to other persons must be licensed, and in answer 9 that providing a registered office without also acting as company secretary still requires a licence.

What it costs: carrying on the business unlicensed is an offence under section 53F — a level 6 fine (HK$100,000) and six months’ imprisonment, and the magistrate may additionally disqualify the person from holding a licence. A landlord letting premises needs no licence (answer 11); the dividing line is whether the address is supplied as a service.

Mistake 2. Closing the transaction or the appointment before the Registrar approves it

Sections 53S, 53T and 53U prohibit a person from becoming an ultimate owner, a partner or a director of a licensee without the Registrar’s prior written approval. The application is made by the licensee itself. The offence crystallises at the moment the person acquires the status, not when the Registrar learns of it. It is framed as a contravention “without reasonable excuse”, but approval obtained afterwards is not itself such an excuse. The offence falls on the person who acquired the status, even though the approval application is made by the licensee.

What it costs: a level 5 fine (HK$50,000) and six months’ imprisonment for each contravention. This is not a theoretical exposure: the prosecution dated 14 September 2023 included charges under section 53S(1) and section 53U(1), six counts, at HK$4,000 each.

Mistake 3. Filing the renewal later than 60 days before expiry

Section 53K(2)(a) requires the renewal application to be made not less than 60 days before the expiry date. The protective mechanism in section 53K(4) — the licence remains in force until the renewal is granted or a refusal takes effect — only engages where the application was made in time. File late and the protection never attaches, so from the expiry date the business is unlicensed.

What it costs: the file moves from the renewal track to the grant track. For a corporation with two directors and one ultimate owner the fee difference is HK$6,365 against HK$5,835 — but the real cost is the unlicensed interval, every day of which is potentially caught by section 53F.

Mistake 4. Budgeting a fee “per licence” rather than “per tested person”

Item 3 of Schedule 3A sets the grant fee at HK$3,440 plus HK$975 for each person whose fitness and propriety is assessed. The renewal fee is HK$2,910 plus the same HK$975 per person. The separate fees in items 5 to 7 of Schedule 3A fall due later — HK$1,140 for each approval of a new ultimate owner, partner or director.

What it costs: for a corporation with two directors and one ultimate owner the actual grant fee is HK$6,365 — HK$2,925 above the headline figure. In a multi-tier ownership chain the population of tested persons grows, and the fee grows with it.

Mistake 5. Reading 120 days as calendar days

Paragraph 4.7.3 of the current Guideline on Anti-Money Laundering and Counter-Terrorist Financing (For TCSP Licensees), March 2025 edition, is expressed in working days: identity verification should be completed within 30 working days, the business relationship should be suspended once 30 working days have passed, and terminated once 120 working days have passed.

What it costs: converted to calendar days, the firm terminates roughly two months earlier than required — or, where the same error runs the other way in another procedure, retains the client beyond the limit and departs from the guideline. Failure to follow a guideline does not of itself create liability under section 7(4), but the guideline is admissible in evidence and must be taken into account by the court.

Mistake 6. Treating a CDD failure as a criminal matter — and under-weighting publication

The offences in section 5(5) to (8) are addressed to a financial institution. Section 5A applies Schedule 2 to DNFBPs, which include a TCSP licensee, but creates no offence of its own. A licensee’s exposure for a Schedule 2 breach is disciplinary, under section 53Z: public reprimand, a remedial order and a pecuniary penalty capped at HK$500,000.

What it costs: the error runs in both directions. Firms overstate a custodial risk that does not exist in this configuration, and at the same time understate section 53Z(6) — the Registrar publishes the action taken. The twenty published disciplinary cases between September 2024 and June 2026 carry penalties from HK$4,000 to HK$32,000, with a median around HK$10,000: the monetary element is modest, the public element is invariable.

Mistake 7. Relying on the intra-group exemption while charging for the service

In answer 8 of the FAQ the Companies Registry sets out three conditions that must hold together: the service is provided by a group member, no service fee is charged, and the services are provided to group members only. Breach any one of the three — an intra-group service fee above all — and the activity falls outside the exemption.

What it costs: section 53F again. The intra-group character of the relationship is not a defence in itself: the “by way of business” test in answer 7 lists an aim of making a profit as one of its four factors, and an intra-group invoice supplies exactly that factor.

Where the structure changes because a foreign company re-domiciles to Hong Kong, the licensee’s directors and ultimate owners change with it — the mechanics of that procedure are set out separately in re-domiciliation of a company to Hong Kong.

Who needs a TCSP licence, who does not, and when professional review is required

A TCSP licence is not a general status for corporate services. It authorises a defined list of four services, supplied in Hong Kong, by way of business, to other persons. Remove any one of those three elements and no licence is required; keep all three and there is no alternative to the licence.

Who genuinely needs one

Profile	Basis	What constitutes the service
Full-service corporate service provider	Paragraphs (a) to (d) of Part 1 of Schedule 1	Company formation, nominee director and secretary, registered office, nominee shareholder
Business centre or serviced office supplying a registered office to clients	Paragraph (c); answer 6 of the Companies Registry FAQ	The supply of the address to other persons for a fee, on its own
Company providing company secretarial services only, to external clients	Paragraph (b)(i)	Acting as secretary of a corporation, or arranging for another person to act
Professional trustee of an express trust	Paragraph (d)(i)	Acting as trustee, or arranging for another person to act
Partnership of accountants in which at least one partner is not an accounting professional	Section 53B read with the definition of accounting professional	The partnership itself is licensed, yet the accountant partners are not put to the fit-a­nd-proper test
Corporation supplying TCS services that is not a corporate practice of CPAs, an authorized institution or a licensed corporation	Section 53B	The corporation is licensed; its accountant directors are not tested

Who does not

Profile	Basis	The condition that must hold
CPA in sole practice and CPA partnership	Section 53B — accounting professional	The professional status must be current
Practising solicitor and foreign lawyer	Section 53B — legal professional	The same
Authorized institution (a bank)	Section 53B	—
Licensed corporation for which TCS services are ancillary to its principal business	Section 53B	The service must be genuinely ancillary; a standalone corporate services line takes it outside the exemption
Intra-group service centre	Answer 8 of the Companies Registry FAQ	Three conditions together: a group member, no fee charged, services to group members only
Landlord letting premises	Answer 11 of the FAQ	Premises are let; an address is not supplied as a service
Secretary of one’s own family company	Answer 12 of the FAQ	The “to other persons” element is missing
One-off act as nominee shareholder for a relative with no commercial gain	Answer 10 of the FAQ	The “by way of business” element is missing
Preparation of annual returns only	Answer 13 of the FAQ	The service is not within the four paragraphs of the definition

When professional review is required

Four situations need to be worked out before filing rather than after.

First, a multi-tier ownership chain. The definition of ultimate owner in section 53A traces control to individuals through a threshold of more than 25% of capital, profits or voting rights, and through ultimate control over management, and expressly captures holdings through a trust or a bearer share holding. The number of tested persons drives the fee, the timetable and the likelihood of further enquiries.

Second, the boundary of “ancillary” for a licensed corporation. The section 53B exemption covers a licensed corporation that operates a TCS business ancillary to its principal business. The Ordinance does not define where ancillary ends and standalone begins; where corporate services are being built out as a separate line, the risk of recharacterisation is real.

Third, mixed partnerships and corporations with professional participants. The configurations “partnership with at least one non-accountant” and “corporation that is not a corporate practice” produce a counter-intuitive result: a licence is required, but not everyone is tested. Misidentifying the population of tested persons changes both the fee and the set of forms.

Fourth, a foreign element among the tested persons. Answers 14 and 15 of the FAQ confirm that a non-resident ultimate owner and an alternate director are tested like anyone else; section 53I(b) takes into account equivalent overseas convictions, money laundering and terrorist financing offences, and offences whose proof requires a finding of fraud, corruption or dishonesty.

Where the structure involves a family trust and the management of family assets, a separate tax regime sits alongside the TCSP regime — the Hong Kong family office tax concession (FIHV). They are distinct regulations, and neither substitutes for the other.

If you are planning a Hong Kong structure and want to establish in advance whether it falls within the licensing regime, UPPERSETUP assists with company incorporation and ongoing support in Hong Kong.

Frequently asked questions

Do I need a TCSP licence if I only provide clients with a registered office address?

Yes. Providing a registered office, business address, correspondence address or administrative address for a corporation, a partnership or any other legal person or legal arrangement is a service in its own right under paragraph (c) of Part 1 of Schedule 1 to the Ordinance. The Companies Registry confirms this in answers 6 and 9 of the “Licensing requirements” FAQ: a business centre supplying an address to other persons must be licensed even if it does not act as company secretary.

How much does a TCSP licence cost in Hong Kong?

The grant fee is HK$3,440 plus HK$975 for each person whose fitness and propriety is assessed (item 3 of Schedule 3A). The renewal fee is HK$2,910 plus the same HK$975 per person. For a corporation with two directors and one ultimate owner the grant costs HK$6,365 and the renewal HK$5,835. Schedule 3A has not been amended once since it was inserted by Ordinance No. 4 of 2018.

How long is a TCSP licence valid?

Under section 53O a licence is valid for three years unless the Registrar specifies a shorter period. The current Guideline on Licensing of Trust or Company Service Providers, May 2025 edition, describes three years as the normal validity period.

Who has to pass the fit-and-proper test?

It depends on the form. For a sole proprietor: the proprietor and each ultimate owner. For a partnership: each partner and each ultimate owner. For a corporation: each director and each ultimate owner. Section 53H frames the corporate requirement asymmetrically — the applicant corporation itself need not be fit and proper; its directors and ultimate owners must be fit and proper to be associated with the licensee.

What is the penalty for operating without a TCSP licence?

Section 53F: a fine at level 6, which is HK$100,000 under Schedule 8 to the Criminal Procedure Ordinance (Cap. 221), and six months’ imprisonment. The magistrate may additionally make an order disqualifying the person from holding a licence. As at September 2026 the Companies Registry has published no section 53F case at all: all twelve published prosecutions rest principally on section 53ZN(1) — providing false or misleading information.

Can a TCSP licensee be prosecuted for a CDD failure?

No. The offences in section 5(5) to (8) of the Ordinance are addressed to a financial institution. Section 5A applies the Schedule 2 requirements to DNFBPs, which include TCSP licensees, but creates no offence of its own. A Schedule 2 breach exposes a licensee to disciplinary action under section 53Z: public reprimand, a remedial order and a pecuniary penalty not exceeding HK$500,000, and, where a remedial order is not complied with, a further daily penalty of up to HK$10,000 for each day of default after the compliance date.

How far in advance must a renewal application be filed?

Not less than 60 days before the expiry date (section 53K(2)(a)). Where that deadline is met, section 53K(4) keeps the licence in force until the renewal is granted or a refusal takes effect. The renewed period runs from the day after the previous one expired, under section 53K(7), so filing early does not shorten the term.

Does an intra-group service company need a licence?

No, provided the three conditions in answer 8 of the Companies Registry FAQ hold together: the service is provided by a group member, no fee is charged for it, and services are provided to group members only. Charging an intra-group fee destroys the exemption and supplies the “by way of business” element — one of the four factors in answer 7.

Does being a CPA or a solicitor remove the need for a licence?

Individually, yes: an accounting professional and a legal professional are expressly listed in section 53B. But the configuration matters. A partnership in which at least one partner is not an accounting professional must be licensed, yet its accountant partners are not put to the fit-and-proper test. The same applies to a corporation that is not a corporate practice of CPAs: the licence is required and the accountant directors are not tested.

What is the deadline for challenging a Registrar decision?

Within 21 days after the notice of the decision was sent — section 59(1); the application goes to the Anti-Money Laundering and Counter-Terrorist Financing Review Tribunal in writing, setting out the grounds. An extension is available only after both sides have been heard and for good cause. Section 75 generally postpones the decision taking effect until the 21 days expire or the Tribunal disposes of the matter, but contains a public-interest reservation allowing a decision to take effect immediately.

How often must the risk assessment be refreshed?

Paragraph 2.9 of the Guideline on Anti-Money Laundering and Counter-Terrorist Financing (For TCSP Licensees), March 2025 edition, requires the assessment to be conducted every two years and upon trigger events that are material to the licensee’s business and risk exposure.

How many TCSP licensees are there in Hong Kong?

7,412 as at the end of June 2026, with 333 new licences granted in the first half of 2026. The figures come from the Companies Registry statistics release of 17 July 2026. At the end of 2025 the figure was 7,220.

Key takeaways

A TCSP licence is required where the service is supplied in Hong Kong, by way of business, to other persons, and falls within at least one of the four paragraphs of the definition in Part 1 of Schedule 1. Remove any of those elements and the activity sits outside the regime; keep them all and the licence is mandatory.

Supplying a registered office address alone is already a licensable service. This is the most frequent source of error: paragraph (c) of the definition requires neither secretarial work nor company formation alongside it.

Part 5A of the Ordinance has been in force since 1 March 2018 and has been amended twice since — both times by Ordinance No. 15 of 2022. Section 25 of that Ordinance amended section 53A (the definitions); section 26 repealed Division 7 (sections 53ZH to 53ZK). Part 5A carries no other amendment note. Three 2025–2026 instruments frequently mentioned alongside Cap. 615 do not touch Part 5A at all.

The fee is charged per tested person, not per licence. HK$3,440 plus HK$975 per person on grant, and HK$2,910 plus HK$975 on renewal. Schedule 3A has not been amended since 2018.

The fit-and-proper test applies three times: on grant, on renewal, and on every change of ultimate owner, partner or director. Section 53K(3) applies section 53I to renewal; sections 53S, 53T and 53U require the Registrar’s prior approval before the person acquires the status.

A TCSP licensee is not prosecuted for breaching the Schedule 2 requirements. The offences in section 5(5) to (8) are addressed to a financial institution; section 5A applies Schedule 2 to DNFBPs but creates no offence. The exposure is disciplinary, under section 53Z, capped at HK$500,000, with a daily penalty of up to HK$10,000 for failing to comply with a remedial order.

A licensee’s criminal exposure arises elsewhere: operating unlicensed (section 53F), completing a transaction before approval (sections 53S, 53T, 53U), failing to notify (sections 53W, 53X), false information (section 53ZN) and obstructing an inspection (section 10).

The universal ground for a disciplinary case is section 23 of Schedule 2. It was breached in nineteen of the twenty published cases: the regulator sanctions not an isolated error in a customer file but the absence of a system that prevents such errors.

Practice is milder than the statute in money and harsher in publicity. Twenty disciplinary cases between September 2024 and June 2026 produced penalties from HK$4,000 to HK$32,000 against a HK$500,000 cap; twelve prosecutions produced fines of HK$3,000 to HK$10,000 per count, HK$86,000 in aggregate. Every disciplinary decision, however, is published under section 53Z(6).

Guidelines bind as evidence, not as law. Under section 7(4) to (6) a failure to follow a guideline does not of itself give rise to liability, but the guideline is admissible in evidence and must be taken into account, and the regulator must have regard to it.

The appeal window is 21 days, the shortest period in the regime. Under section 75 a decision generally does not take effect until that period expires, although the public-interest reservation allows immediate effect.

Summary 

A TCSP (trust or company service provider) licence in Hong Kong is granted by the Registrar of Companies under Part 5A of the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615), in force since 1 March 2018. The licence is mandatory for any person who, in Hong Kong, by way of business and for other persons, forms companies, acts as director, secretary, partner, trustee or nominee shareholder, or provides a registered office address. Supplying an address alone already requires the licence. The Government, banks, a licensed corporation whose TCS business is ancillary, and accounting and legal professionals are exempt under section 53B. A licence is valid for three years and costs HK$3,440 plus HK$975 for each tested person; renewal costs HK$2,910 plus HK$975 and must be applied for not less than 60 days before expiry. The fit-and-proper test under section 53I applies to the sole proprietor, the partners, a corporation’s directors and every ultimate owner holding more than 25%. Operating without a licence is punishable by a fine of up to HK$100,000 and six months’ imprisonment under section 53F. Breaching the Schedule 2 CDD requirements is not a criminal offence for a licensee: the consequences are disciplinary under section 53Z — public reprimand, remedial order and a pecuniary penalty of up to HK$500,000. At the end of June 2026 Hong Kong had 7,412 TCSP licensees.

Sources

Every link below points to an official Hong Kong legislative text or a Companies Registry publication. The legal position was verified as at September 2026; the consolidated text of Cap. 615 was checked against the version in force on 15 May 2026.

1.        Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615) — full consolidated text

2.        Cap. 615, section 53F — carrying on a business without a licence

3.        Cap. 615, section 53I — fit and proper criteria

4.        Cap. 615, section 53K — renewal of a licence

5.        Cap. 615, section 53Z — the Registrar’s disciplinary powers

6.        Cap. 615, section 59 — application to the Review Tribunal

7.        Cap. 615, section 75 — when a specified decision takes effect

8.        Cap. 615, Schedule 1 — definitions, including trust or company service

9.        Cap. 615, Schedule 2 — CDD and record-keeping requirements

10.    Cap. 615, Schedule 3A — fees for TCSP licensees

11.    Anti-Money Laundering and Counter-Terrorist Financing (Financial Institutions) (Amendment) Ordinance 2018 (Ord. 4 of 2018) — the Ordinance that inserted Part 5A

12.    Anti-Money Laundering and Counter-Terrorist Financing (Amendment) Ordinance 2022 (Ord. 15 of 2022) — the Ordinance that amended Part 5A twice, by ss. 25 and 26

13.    Criminal Procedure Ordinance (Cap. 221), Schedule 8 — level of fines for offences

14.    Companies Registry. Guideline on Licensing of Trust or Company Service Providers (May 2025)

15.    Companies Registry. Guideline on Anti-Money Laundering and Counter-Financing of Terrorism (For Trust or Company Service Provider Licensees) (March 2025)

16.    Companies Registry. Guideline on Imposition of Pecuniary Penalty (March 2018)

17.    Companies Registry. FAQ: Licensing requirements for trust or company service providers (June 2023)

18.    Companies Registry. Index of guidelines for TCSP licensees

19.    Companies Registry. Forms TCSP1 to TCSP7 and their supplementary sheets

20.    Companies Registry. Form TCSP1 — application for a licence (May 2025 revision)

21.    Companies Registry. Highlights of Disciplinary Cases

22.    Companies Registry. Highlights of Prosecution Cases

23.    Companies Registry. Public register of TCSP licensees

24.    Companies Registry releases statistics for first half of 2026 — press release of 17 July 2026

25.    Companies Registry releases statistics for 2025 — press release of 16 January 2026

Disclaimer

This material is provided for information only and does not constitute legal, tax, financial, investment or consulting advice. Before acting on it, obtain individual professional advice that takes into account your particular circumstances, jurisdiction, corporate status and the regulators’ current requirements.

Publication date: September 2026.