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TCSP services / HMRC register

The Money Laundering Regulations 2017 require a register to be maintained by HMRC of all persons who are trust or company service providers (TCSPs). It is a criminal offence for a person to act as a TCSP without being on the register.

What is the TCSP register?

The Money Laundering Regulations 2017 requires HMRC to maintain a register of persons who are trust or company service providers. It is a criminal offence for a person to act as a TCSP without being on the register.

Persons are added to the register by their AML/CTF supervisor. HMRC is in the process of establishing this register and will liaise with AML/CTF supervisors to ensure relevant supervised members are on the register.

What is a TCSP?

A trust or company service provider is defined in the Regulations as providing by way of business any of the following services:

- forming companies or other legal persons

- acting, or arranging for another person to act (i) as a director or secretary of a company; (ii) as a partner of a partnership; or (iii) in a similar capacity in relation to other legal persons

- providing a registered office, business address, correspondence or administrative address or other related services for a company, partnership or any other legal person or legal arrangement

- acting, or arranging for another person to act, as (i) a trustee of an express trust or similar legal arrangement; or (ii) a nominee shareholder for a person other than a company whose securities are listed on a regulated market.

Please see regulation 12(2) for the full definition.

Please note that a person is still a TCSP even if they provide any of the above services incidentally to other services, or provide them infrequently or on a one-off basis.

I have informed you I am a TCSP on the AML/CTF return. Do I need to do anything further?

No, if you answered on the AML/CTF return that you are a TCSP then you do not need to do anything further. We will pass on the relevant information to HMRC so that you are on the register.

I was not acting as a TCSP, but I will start acting as one. What should I do?

You must inform us before you begin to act as a TCSP. You can inform us by email at aml@aicpa-cima.com.

Once we have added you to HMRC’s register we will confirm this with you. You must not start acting as a TCSP until you have received our confirmation, as it is a criminal offence to act as a TCSP unless you are on the register.

I may start acting as a TCSP. Can I be added to the register?

Yes, you can inform us by email at aml@aicpa-cima.com.

Once we have added you to HMRC’s register we will confirm this with you. You must not start acting as a TCSP until you have received our confirmation, as it is a criminal offence to act as a TCSP unless you are on the register.

I am no longer a TCSP. How can I be removed from the register?

If you are no longer a TCSP you can inform us by email at aml@aicpa-cima.com.

Once we have removed you from the register we will confirm this with you. If you will be acting as a TCSP again, you must inform us so we can add you to the register.

I am supervised for AML/CTF by another supervisor. How can I be added to the register?

Persons are added to the register by their supervisor. If CIMA is not your supervisor you should follow your own supervisor’s procedure to be added to the register.