1. The functions and regulations of Hong Kong TCSP license
Type 1: General corporate services
Mainly authorized to provide establishment of corporations、Provide registered/business address，and serve or arrange for others to serve as directors of the company、Basic corporate services such as secretarial and nominee shareholder parties。
Type 2: Trust and virtual asset custody
Authorization to act as trustee of an "express trust"。Over-the-counter trading of virtual assets in accordance with the law (OTC) and the underlying structure of the compliant trust custody model，Help open bank VA account。
Stringent AML/CTF statutory compliance
Subject to the Anti-Money Laundering and Counter-Terrorist Financing Ordinance(AMLO) Chapter 615。Enforce high standards of customer due diligence (CDD)、Transaction Monitoring and Travel Rule。
Criminal penalties for operating without a license
Unlicensed operations are strictly prohibited according to law。Pursuant to AMLO Section 53F(1) strip，It is a crime to operate TCSP business in Hong Kong without a license，Once convicted，Facing a maximum fine of HK$100,000 and 6 months' imprisonment。
2. Application conditions and financial requirements for TCSP license
| Review feature categories | Legal standards and definition of exemption objects |
|---|---|
| Legal registered capital requirements (trust corporation) | According to the Trustees Ordinance，If registered as a trust company，Its issued share capital shall not be less than 3,000,000 Hong Kong dollar，And must pay at least the same amount in cash，Or provide bank deposit certificate。General Type 1 There is no statutory specific capital limit for corporate services。 |
| Statutory exemptions from applying for a license | Pursuant to Article 53B AMLO：accreditation body (bank)、Operating in Hong Konglicensed corporation (SFC licensed，And TCSP is an affiliated business)、accounting professionals (Certified Public Accountant/Practicing Corporation)、legal professionals (Lawyer/foreign lawyer)。 |
| Compliance obligations for exempt persons | The above-mentioned professionals who are exempted from applying for TCSP license，When providing trust or company services，Full compliance with the AMLO Schedule is still required by law 2 Customer due diligence as set out in (CDD) and stringent record-keeping requirements。 |
3. [Fit and proper person] as prescribed by the Companies Registry (Fit & Proper) Review standards]
Legal review objects：All sole proprietors、Partner、Directors and "ultimate owners" (Ultimate Owner)” are required to submit a TCSP4 or TCSP5 statement to the Director in accordance with the law to undergo strict background checks (except for professionals who qualify for the aforementioned exemption)。
Define the ultimate owner：Legally refers to directly or indirectly owning/controlling a corporation 25% The above issued share capital，or have the right to exercise 25% Voting rights above，or the natural person who exercises ultimate management control。The holding company itself does not fall into this category，Must penetrate to natural person。
Legal grounds for refusal (Reason for disqualification)：Have been convicted of AMLO offenses、Terrorist financing、Drug trafficking or serious organized crime；Have committed an overseas money laundering or dishonesty fraud offense；or are undischarged bankrupts and corporations in liquidation，Will be directly refused license according to law。
Change approval red line：Any person becomes the new ultimate owner of the licensee’s business、Before partner or director，Must obtain prior written approval from the Director。Violators without reasonable excuse may be fined HK$50,000 and imprisoned for 6 months。
4. Information required to apply for Hong Kong TCSP license
| File category | Legal requirements submission details and compliance interpretation |
|---|---|
| Basic corporate and personnel due diligence documents | Copy of valid business registration certificate。Director and senior management biographies。All statutory "fit and proper statements" that need to be completed and signed by the reviewer(Table TCSP4 / TCSP5)。 |
| Commercial and anti-money laundering internal control system | business plan。AML/CTF Policy and Procedure Manual in compliance with AMLO Schedule 2 (covering Enhanced Due Diligence EDD、Sanctions Screening、STR suspicious transaction reporting process and risk management measures)。 |
| Documentation proving specific qualifications | If you apply to become a trust company，Must provide no less than 300 Bank deposit/capital injection certificate of 10,000 Hong Kong dollars。If the director/shareholder is an exempt professional，A copy of the professional qualification certificate must be submitted。 |
5. Application process and approval steps
first stage：Entity establishment and document preparation (about 3-4 week)
Complete Hong Kong limited company registration。Write AML/CTF policy and business plan。Compile background information and “fit and proper” declaration documents for all directors and UBOs。
second stage：Formal submission of application to the Registrar's Office
Submit Form TCSP1 and its attachments through the TCSP online system or in person，and make a one-time payment 3,440 Hong Kong dollar application fee and 975 Background check fee in HKD/person。
The third stage：Statutory review and supplementary inquiries (about 3-6 months)
Companies Registry’s AML Policy on Submissions、Strict review and verification of financial soundness and executive background，During this period, supplementary material inquiries may be issued.。
Stage 4：Approval and inclusion in the roster
After passing the review，The Director shall grant licenses in accordance with the law。The name and business address of the licensee will be publicly included in the "Register of Trust or Company Service Provider Licensees"。
The fifth stage：Daily compliance supervision after licensing
The license is usually valid for 3 Year。Licensees must unconditionally cooperate with the Companies Registry’s irregular spot checks on business premises and AML/CDD file inspections。
6. virtual assets(VA)business、Trust Segregation and [Legal Compliance Red Line]
VA Account Fund Segregation Legal Requirements：In OTC or token custody business，The TCSP license allows holding customers’ legal currency/virtual assets in a trust model。Separate trust sub-accounts must be established，It is strictly prohibited to mix it with the company’s own funds。
VASP/SFC regulatory boundaries：TCSP is only applicable to pure trust and corporate agency services。If you directly operate a virtual asset trading platform (VATP)，Must report to the Securities and Futures Commission of Hong Kong in accordance with the law (SFC) Apply for a VASP license with extremely high threshold。
On-site inspection and record keeping red lines：The Registrar has the right to enter the business premises of the licensee at any time to inspect and copy transaction records。Legal records (including CDD due diligence drafts) must be properly kept for at least 5-6 Year。Failure to cooperate with an inspection is a criminal offense。
Notification of changes to statutory red lines：Name of licensee、address、Any changes to executive or UBO details，Must be after the change occurs 1 Submit form TCSP6 within one month to report in accordance with the law，Violators without reasonable excuse will be fined HK$50,000。
7. Hong Kong TCSP license application fee and shell company transfer price
| M&A stage / review elements | Legal procedures and practical operation timetable | Market M&A Budget Estimation (HKD) |
|---|---|---|
| Subject matter search and due diligence | Search for compliance targets in the list of licensees。Implement strict legal and financial due diligence，Verify AML breach records and potential hidden liabilities (about 1-2 months)。 | Due diligence and consulting fees：10Ten thousand – 3010,000 Hong Kong dollars |
| Equity Valuation and Transaction Structure | Sign equity acquisition agreement。Consideration evaluation and negotiation for pure TCSP licensed shell companies (about 1 months)。 | Subject matter valuation：50Ten thousand – 20010,000 Hong Kong dollars |
| Regulatory approval and equity delivery | New shareholders/new directors submit form TCSP3 in accordance with the law to receive the "fit and proper person" prior approval from the Companies Registry。After approval, handle share transfer and delivery and legal change notification (about 1-3 months)。 | Statutory approval fee：Thousands of Hong Kong dollars；Handover fee：5Ten thousand – 2010,000 Hong Kong dollars |
8. Hong Kong TCSP license of Hong Kong Huitong，Agency application service
New license application and corporate establishment
Handle Hong Kong limited company registration and structure establishment。Legally match compliant directors who meet the Companies Registry’s “fit and proper” requirements，Fully authorized agent to submit Form TCSP1 to the Registrar and respond to substantive inquiries。
AML internal control system and review coaching
Write a Strictly Compliant AMLO Schedule 2 Required Anti-Money Laundering Compliance Manual。Develop CDD/KYC review forms and suspicious transactions that comply with statutory requirements (STR) Internal transfer reporting process。
Compliance Shell Company M&A and Closing
Assist in searching for clean TCSP licensed shell companies with no illegal liabilities。Handling in-depth legal and financial due diligence，Full authority to submit UBO/director change approval and equity transfer statutory document delivery to the Director。
9. Hong Kong trust or company service provider (TCPS) License plate FAQ answers
According to the Anti-Money Laundering Regulations，Provided on a business basis in Hong Kong：Establish a corporation、Provide registered/business address、Serve as corporate director/secretary、Serves as express trust trustee and nominee shareholder，All fall within the scope of regulation。
There is no minimum statutory capital requirement for regular corporate agency services。If it is registered as a "trust company" in accordance with the law to operate exclusive trust and custody business，According to the Trustee Ordinance, its issued share capital must not be less than 300 10,000 Hong Kong dollars。
Pursuant to Article 53B AMLO，government agency、accreditation body (bank)、SFC licensed corporations operating subsidiary businesses in Hong Kong、and statutory accounting professionals and legal professionals，Legally exempt from applying for a license。
Absolutely prohibited。TCSP is only applicable to trust model custody and enterprise ancillary services。Directly operate DeFi protocols or virtual asset matching transactions，Within the jurisdiction of SFC，Must apply for stringent VASP and securities trading licenses separately。
The official application fee is 3,440 Hong Kong dollars (renewed as 2,910 Hong Kong dollar)。also，For each natural person or corporation that is legally required to undergo a "fit and proper" background assessment，Additional payment per person is required 975 Examination fee in Hong Kong dollars，Fees are non-refundable。
Because banks are extremely strict about crypto funds，A copy of the TCSP license is required、Complete AML/CTF policy，And submit legal documents to prove that the business adopts the trust isolation mechanism，Ensure the absolute physical separation of client funds and the company’s own funds。
New entity application and compliance review usually require 3-6 months (the total period is about 6-10 months)。If equity mergers and acquisitions are implemented，Combined with legal due diligence, apply to the director for UBO/director change approval，The total delivery period is usually 5-9 months。
According to AMLO No. 9 strip，Law enforcement officers have the right to enter business premises at any time。Focus on customer due diligence (CDD) Manuscript、Transaction monitoring process and compliance records。Refusal to cooperate with the inspection and surrender of documents is a criminal offence。
"Pre-approval" must be implemented。Any person becomes the new ultimate owner of a licensed corporation、Before partner or director，Form TCSP3 must be submitted to obtain written approval from the Director。Without reasonable excuse, "getting on the bus first and paying the ticket later" may be punished by fines and imprisonment。
The license is usually valid for 3 Year。If the licensee wishes to continue operating，Must be issued before the license expires 60 on or before，Submit form TCSP2 to apply for renewal in accordance with the law。Failure to submit on time will result in automatic license expiration.。
The Director has the legal authority to take disciplinary action。including public condemnation、Issue a time-limited correction order，and impose a maximum fine of up to 500,000 Huge administrative fine in Hong Kong dollars，In serious cases, the license will be revoked directly。
Must be before the date of proposed closure of business，Notify the Director of the intention to cease operations and the specific date through Form TCSP7 in accordance with the law。The Registrar will formally cancel his license and remove him from the register on that date。Failure to report a violation is a crime。
