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Trust and company service providers (TCSPs) - Thematic Review, guidance and information

Author: ICAEW Regulation

Published: 26 Nov 2021

This short animation will help firms identify the money laundering risks that can be linked to offering trust and company services. It also explains how to mitigate and avoid risks.

About this TCSPs guidance

This guidance is taken from the ICAEW TCSPs Thematic Review 2021 which we carried out earlier in 2021. It forms part of our work as an anti-money laundering supervisor.

This review was undertaken to:

  • assess the nature of the TCSP services offered by the firms we supervise for anti-money laundering; and
  • explore the risks that these services may be used to facilitate money laundering.

We asked firms about the TCSP services they provide and whether those services are in conjunction with accountancy services. We also asked them to describe their assessment of the risks TCSP services present, how they adapt their procedures to mitigate those risks and the number of Suspicious Activity Reports (SARs) they had submitted.

More detail about our methodology is available in the report.

This review sets out the qualitative and quantitative data and trends we observed from the survey responses and guidance for firms on how they can identify, mitigate and avoid risks.

The most common TCSP services provided by our firms are company formation and the provision of a registered office address for clients. All firms providing TCSP services offer these services alongside other accountancy services.

Our firms stated that they would not provide TCSP services unless they saw a clear business rationale for it and where they had an ongoing business relationship with the client. When assessing the money laundering risks our firms consider several factors. This assessment impacts their decisions as to whether to continue with the business relationship.

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