How to register as a trust or company service provider

If you intend to offer a "registered office" or "service address" to your clients, you must notify your Anti-Money Laundering (AML) supervisor and be included on the Trust or Company Service Provider (TCSP) register before you start. Failing to do so is a breach of the Money Laundering Regulations and can result in significant fines or even criminal prosecution.

What is a TCSP?

In the eyes of the law, a Trust or Company Service Provider is any business that helps others set up companies or provides them with a business address. For many new accountants or virtual assistants, this usually means allowing clients to use your office (or home) address as their official legal address with Companies House. Because this service can be misused by criminals to create "shell" companies, the government keeps a strict register of everyone providing it.

Identify your supervisor

Before you register, you need to know who looks after your AML compliance. This depends on how you have set up your business:

• Professional Bodies: If you are a member of a body like AAT, ACCA, or ICAEW, they are usually your supervisor.
• HMRC: If you are not a member of a professional body, you will likely be supervised directly by HMRC.

The "Fit and Proper" test

To be on the register, you (and any other "beneficial owners" or managers in your business) must pass a Fit and Proper test. This is a background check to ensure that the people running the business are honest and reliable. You will typically need to provide details of any past criminal convictions or financial issues (like bankruptcy).

How to complete the registration

The process differs slightly depending on your supervisor, but generally follows these steps:

1. Check your current status: If you are already registered with HMRC for AML, log in to your HMRC online account to see if you are already listed as a TCSP.
2. Notify your supervisor: If you are with a professional body, contact them directly. Most have a specific form to add TCSP services to your existing practice licence.
3. Submit the application: You will need to confirm which specific services you are offering (e.g., acting as a formation agent or providing a registered office).
4. Pay the fee: There is often a small additional fee to be added to the register. HMRC, for example, charges for the Fit and Proper test per person.
5. Wait for confirmation: You cannot legally offer these address services until you receive confirmation that you have been added to the register.

Top Tip: If you are supervised by a professional body, they are legally required to pass your details to HMRC to be included on the central TCSP register. Check the public TCSP register on the GOV.UK website after a few weeks to ensure your business name appears correctly.

Best practices for TCSPs

Once registered, you have an ongoing duty to keep your records up to date. If you move premises, change your business name, or appoint a new director, you must notify your supervisor within 30 days. If you stop offering address services, you should also ask to be removed from the register to avoid unnecessary fees or inspections.