Hong Kong Trust & TCSP License
Applications and Acquisitions

One-stop TCSP license and trust company registration consulting services

Aiying is committed to providing clients with a complete "one-stop" license application and consulting service for their crypto businesses. We possess extensive market experience, in-depth regulatory knowledge, and strong business acumen to help clients provide practical, thoughtful, and efficient solutions.

Select your path

TCSP License

Low threshold

Trust or Company Service Provider License

Suitable scenarios:
  • Provide company secretarial and registered address services
  • Arrange for someone else to act as trustee
  • VASP platform affiliated hosting company
  • OTC Virtual Asset Custody Service

6-8

Application period of one month

No

Minimum capital requirements

Trust Company Registration

High threshold

Directly acting as trustee to manage trust property

Suitable scenarios:
  • Family office asset management
  • Directly managing client trust assets
  • Heritage planning and preservation services
  • Directly manage virtual asset trusts

6-9

Application period of one month

150 million

Hong Kong dollar capital + guarantee

Comparative Analysis

Detailed comparison of the two systems

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License Acquisition

Quick start of business

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VASP combined

Virtual asset applications

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FAQs

Quick Q&A

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Overview of Licensing and Registration

Understanding the basic concepts of TCSP license and trust company registration

What is a TCSP license?

The Hong Kong TCSP (Trust or Company Service Provider License) is a licensing regime implemented under the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (AMLO, Chapter 615) to regulate companies and individuals providing trust or company services in Hong Kong. This license has been issued since March 1, 2018.

legal basis

Anti-Money Laundering Ordinance
Chapter 615

regulatory agency

Companies Registry
(CR)

Implementation time

2018 January 3
Officially effective

Core business scope

Establishment of legal entity

Incorporation or other legal entity

Appoint or appoint a director/secretary

Appoint or arrange for others to serve as company directors, secretaries, partners, or other similar positions.

Provide registration address

Provide a registered office, business address, mailing address, or administrative address.

Act as or arrange trustee

Acting as or arranging for another person to act as trustee of an express trust

Acting as or arranging a nominee shareholder

Acting as or arranging for someone else to act as a nominee shareholder of the company

important:TCSP licensees can "arrange for others" to act as trustees, but if they want to directly act as trustees to manage trust property, they must register as a separate trust company.

What is trust company registration?

Trust company registration is a registration system stipulated in the Trustees Ordinance (Chapter 29), which allows companies to directly act as trustees to manage trust property. Institutions registered as trust companies can provide clients with professional trust management, asset protection, and wealth transfer services.

legal basis

Trustee Regulations
Chapter 29

regulatory agency

Companies Registry
(CR)

Implementation time

1934
Long history

Core business scope

Directly act as trustee

Directly managing clients' trust assets

Family Trust Management

Providing trust management services for high-net-worth families

Asset protection

Protecting client assets through a trust structure

Wealth inheritance

Assisting clients with intergenerational wealth transfer planning

Portfolio Management

Managing investment portfolio as trustee

Estate Administration

Serving as executor and estate administrator

Core advantages:Trust companies can directly manage clients' trust assets without going through a third party. This is crucial for scenarios such as family offices, high-net-worth client asset management, and virtual asset trusts.

TCSP License vs. Trust Company Registration

A comprehensive comparison of the core differences between the two regulatory systems

Core Differences Comparison

Comparison Dimensions
TCSP License
Trust Company Registration
Legal basis Chapter 615 of the Anti-Money Laundering Ordinance Chapter 29 of the Trustee Ordinance
Regulatory Focus AML/CTF compliance Trust management capabilities and financial soundness
Application duration 6-8 months 6-9 months
Minimum capital No official regulations HK$300 million subscribed capital
Guarantee requirements 无 HK$150 million (bank guarantee or insurance)
Official fees Application fee starts from HK$3,440, and annual fee starts from approximately HK$2,910 (depending on the number of suitable candidates tested). Application fee + annual fee: approximately HK$5,200/year
Core Business Company secretary, registered address, appointment of trustee Directly acting as trustee to manage trust assets
Typical customers Enterprise service provider, VASP affiliate Family offices, high-net-worth clients

Key features of a TCSP license

✓ Low entry barrier, no minimum capital requirement

✓ The application process is relatively short (6-8 months).

✓ You can arrange for someone else to act as the trustee.

✓ Suitable for enterprise services and VASP affiliates

✗ Cannot directly act as trustee

✗ Cannot directly manage trust assets

Key features of trust company registration

✓ Can directly act as trustee

✓ Can directly manage client trust assets

✓ Suitable for family offices and wealth management

✓ The supervision team has a long history and high reputation.

✗ The threshold is relatively high (HKD 150 million guarantee).

✗ The application process takes a long time (6-9 months).

Which one should I choose?

If you choose a TCSP license, you should:
  • Primarily provides business services such as company secretarial services and registered address.
  • Provide ancillary hosting services for the VASP platform (by arranging for others to act as trustees).
  • We want to launch our business quickly, but our budget is limited.
  • No need to directly manage clients' trust assets
If you choose to register a trust company, and you:
  • Need to directly act as trustee to manage client trust assets
  • Providing family office services for high-net-worth clients
  • Offering services such as wealth transfer and estate management.
  • With sufficient capital (HK$150 million) and long-term planning
💡 Best option: Hold both

A company can hold both a TCSP license and a trust company registration simultaneously, allowing it to offer the most comprehensive services: providing corporate services while directly managing trusts. Many companies adopt a progressive strategy of "TCSP first, trust later," starting their business with lower barriers to entry and then applying for trust company registration as their business grows.

TCSP and Trust Companies: A Relationship Analysis

To gain a deeper understanding of the relationship, differences, and connections between the two and avoid common misunderstandings.

Explanation of core relationships

TCSP License

The company's "business license"

  • Supervisory Authority: Company Registrar
  • Legal basis: Chapter 615 of the Anti-Money Laundering Ordinance
  • Services include: company secretary, registered address, nominee director, etc.
  • Capital requirements: No minimum requirement
Trust Company Registration

The "business license" for trust services

  • Supervisory Authority: Company Registrar
  • Legal basis: Chapter 29 of the Trustee Ordinance
  • Scope of business: Acting as trustee to manage trust property
  • Capital requirement: 300 million RMB subscribed capital + 150 million RMB guarantee

Key takeaways

Independent regulatory system

Although both are regulated by the Companies Registry, their legal bases differ.

Can be held simultaneously

Choose according to business needs, not in order of priority.

Business scope does not overlap

TCSP cannot provide trust services, and vice versa.

Clarification of Common Misconceptions

Price does not includeA TCSP license only allows the provision of company services (such as company secretary, registered address, nominee director, etc.), and does not permit the holder to act as a trustee to manage trust property.

To provide trust services, a separate registration as a trust company is required. The scope of business for both is governed by different laws and regulations and is not mutually exclusive.

Depending on your business scope:

  • Providing only company services → Only a TCSP license is required
  • Trust services only → Only trust company registration required
  • Both are offered → Requires simultaneous holding

Many companies adopt a "TCSP first, trust later" strategy, starting their business with a lower threshold and then applying for trust company registration as the business develops.

There is no fixed order; it is recommended to decide based on the following factors:

  • Business Priority
    Apply for whichever service you want to do first.
  • Funding
    Trust companies require a HK$150 million margin deposit, with even higher capital requirements.
  • time schedule
    You can apply at the same time, or you can apply gradually.

It is somewhat helpful.But it is not the decisive factor:

  • Advantage
    The established compliance system and the "suitable candidate" qualification can be reused, and the regulatory authorities already have an understanding of the company.
  • Still need to meet
    Independent requirements for trust companies (300 million RMB subscribed capital, 150 million RMB guarantee, trust business experience, and an independent compliance system).

Depending on the business model:

  • Custodial Model (Holding VA on Behalf of Clients)
    Required: TCSP license + VASP license
  • Trust model (managing VA as a trustee)
    Required: Trust company registration + VASP license
  • Integrated services (both are provided)
    Required: TCSP license + Trust company registration + VASP license

Business Scenario Comparison Table

Quickly determine which qualification is required based on the specific business scenario.

Business Scenarios TCSP license required Trust company registration is required. Explain
Provide company secretarial services ✔ ✖ TCSP Core Business
Provide registered address service ✔ ✖ TCSP Core Business
Acting as a nominee director/shareholder ✔ ✖ TCSP Core Business
Acting as trustee to manage the trust ✖ ✔ Core Business of Trust Companies
Managing a family trust ✖ ✔ Core Business of Trust Companies
Provide custody services for the VA exchange ✔ ✖ TCSP + VASP required
Managing VA through a trust ✖ ✔ Requires a trust company + VASP
Comprehensive wealth management services ✔ ✔ Both are needed

Combination strategy recommendations

Choose the most suitable application strategy based on your situation.

Strategy A
First TCSP, then trust

Suitable for: Individuals with limited initial capital who wish to launch their business quickly.

Reduce initial investment

Quick start of business

Expand after establishing a compliance foundation

Strategy B
Trust first, then TCSP

Suitable for: Individuals with existing trust business experience and sufficient funds.

Directly enter the high-value market

Establish a high-end brand image

Applying for TCSP afterward is relatively easy.

Strategy C
Apply at the same time

Suitable for: Individuals with sufficient funds and a clear business plan.

Complete all qualifications in one go

Save time on repeated applications

High initial investment and high manpower requirements

Application eligibility requirements

Understand the specific requirements for TCSP licenses and trust company registration.

Company Qualification

Hong Kong registered company

Must be incorporated in Hong Kong

Hong Kong Business Locations

Having a physical place of business in Hong Kong

Sufficient financial resources

Possess the financial capacity required to operate the business (no minimum amount required).

Personnel Requirements

Suitable candidate test

Directors, shareholders, and responsible personnel must go through

Compliance Officer

At least one full-time compliance officer

Money Laundering Reporting Officer

At least one money laundering report officer

Company Qualification

Hong Kong registered company

Must be incorporated in Hong Kong

Hong Kong Business Locations

Having a physical place of business in Hong Kong

HK$300 million paid-in capital

The full amount must be actually paid; a pledged payment is not acceptable.

HK$150 million guarantee

Bank guarantee or professional liability insurance

Personnel Requirements

Suitable candidate test

Directors, shareholders, and responsible personnel must approve (the requirements are more stringent).

Compliance Officer

At least one full-time compliance officer

Money Laundering Reporting Officer

At least one money laundering report officer

Trust management experience

Directors and senior executives should have relevant experience in trust management.

Financial Requirements Explanation

The financial requirements for registering a trust company are significantly higher than those for a TCSP license.

  • HK$300 million subscribed capital
  • HK$150 million guarantee: This can be a bank guarantee or professional liability insurance.
 

"Suitable Candidate" Test (Both applicable)

The Companies Registry's core assessment criteria for applicants

  • Honesty and integrity
  • No criminal record (especially related to money laundering, fraud, or corruption).
  • No bankruptcy or liquidation record
  • No history of violating supervision regulations
  • Good business reputation and integrity record
  • Relevant industry work experience (trust, corporate services, finance, etc.)
  • Understanding and enforcement capabilities of AML/CTF regulations
  • Management and supervision capabilities
  • Professional qualifications (such as lawyer, accountant, and trust practitioner qualifications)
  • The company has sufficient financial resources
  • No significant debt or financial difficulties
  • Able to continue operating and fulfill obligations
  • Note: TCSP has no minimum capital requirement, but trust companies need a deposit of HK$150 million.

Detailed application process

The complete path from preparation to obtaining a license

6-10

Total duration per month

14+

Application documents

3,440

Official Hong Kong Dollar Fees/Year

Preliminary preparation

3-4 months

Establish a Hong Kong company and ensure it meets the basic qualifications

Hire or appoint a compliance officer and a money laundering reporting officer.

Develop AML/CTF policies and internal control procedures

Prepare company bylaws and organizational structure documents

Document preparation

2-3 weeks

Fill out the TCSP1 application form

Prepare personal documents for directors, shareholders, and responsible personnel.

Prepare business plans and compliance manuals

Prepare financial supporting documents

Submit application

1 weeks

Submit complete application materials to the Companies Registry

Pay the application fee (starting from HK$3,440, depending on the number of suitable candidates to be tested).

Application acceptance confirmation

Awaiting review feedback

Review and Interview

2-3 months

Companies Registry reviews application materials

Additional documents or clarifications may be required.

Interviews with directors and responsible personnel (if required)

Appropriate candidate assessment

License issued

1-2 weeks

Received approval notification

Pay the first year's license fee (from approximately HK$2,910).

Obtain TCSP license certificate

Publicly registered on the Companies Registry website

6-9

Total duration per month

20+

Application documents

5,200

Official Hong Kong Dollar Fees/Year

Preliminary preparation

1-2 months

Establish a Hong Kong company and subscribe for HK$300 million in share capital.

Arrange a bank guarantee or professional liability insurance of HK$150 million.

Recruiting directors and senior executives with trust management experience.

Develop trust management policies and AML/CTF procedures

Document preparation

1-2 month

Fill out the trust company registration application form

Prepare detailed personal and professional background documents for directors and shareholders.

Provide 150 million guarantee documents

 

Preparation of Trust Business Plan and Risk Management Framework

Submit application

1 weeks

Submit complete application materials to the Companies Registry

Pay the application fee (approximately HK$5,200).

Submit financial proof and guarantee documents

Awaiting review feedback

Review and Interview

3-4 months

The Companies Registry conducts in-depth reviews of financial and management capabilities.

Additional documents or further explanations may be required.

Interviews with directors and senior executives (with a focus on assessing trust management experience).

Appropriate candidate testing (with stricter standards)

Get registered

1-2 weeks

Received approval notification

Pay the first year's registration fee (approximately HK$5,200).

Obtain the trust company registration certificate

Publicly registered on the Companies Registry website

Official Fee Comparison

The following are the official fees stipulated by the Companies Registry (please consult for a customized quote on other costs).

TCSP License Official Fees

Application fee

From HK$3,440

First year license fee

From HK$3,440

Annual license renewal fee

From HK$3,440

Official fees for registering a trust company

Application fee

Approximately HK$5,200

First year registration fee

Approximately HK$5,200

Annual renewal

Approximately HK$5,200

Additional financial requirements

HK$150

Note:The above are official fees and do not include consulting fees, document preparation, compliance system setup, or other costs. For a complete cost structure, please contact us for a customized quote.

License Acquisition Guide

A quick market entry alternative (primarily applicable to TCSP licenses)

Note: License acquisition primarily applies to TCSP licenses. Trust company registration is more difficult to acquire due to the HK$450 million financial requirement and stricter management capacity review, and there are fewer available targets in the market. The following content mainly focuses on TCSP license acquisition.

save time

5.5-9
Months vs. 6-10 months for new applications

Existing customers

Instant income
Inheriting the existing customer base

Banking Relationships

Established
Avoid difficulties in reopening an account

Acquisition process overview

Demand analysis and market search

Identify business needs, search for licensed companies, and assess financial and customer base.

1-2 months

due diligence

A comprehensive legal, financial, and operational review confirmed that there were no irregularities or hidden debts.

1-2 months

Negotiation and deal structuring

Valuation negotiation, transaction structure design, and signing of legal documents.

1-2 months

Supervision Approval and Changes

Submitting shareholder/director changes and conducting fit-the-jobs tests to the Companies Registry

1-3 months

Transaction completion and handover

Settle payments, receive customer information, and ensure ongoing compliance.

0.5-1 months

Key considerations

Supervision risks

No violations have been confirmed; however, historical compliance issues may affect the acquisition.

financial risk

A comprehensive due diligence process was conducted to rule out hidden debts, pending litigation, and tax issues.

operational risks

Assess customer churn, employee stability, and system compatibility.

Banking Relationships

Transfer of banking relationships may require a review and thorough documentation.

Cost Explanation: The cost of acquiring a license varies depending on factors such as the target company's customer base, business scale, and brand value, and there is no fixed price. For specific acquisition opportunities and pricing information, please contact us for customized solutions.

Combined application of TCSP and VASP

Innovative Applications in the Virtual Asset Field and the "TCSP First, VASP Later" Strategy

Why is TCSP+VASP needed?

The TCSP license and the VASP license are two separate regulatory systems. The TCSP is regulated by the Companies Registry, while VASPs are regulated by the SFC. According to Hong Kong's SFC regulations, if a virtual asset trading platform (VATP) chooses to hold clients' funds and virtual assets in trust through a subsidiary, that subsidiary must hold a TCSP license. Not all VASP platforms require a TCSP license; it is only necessary to hold one under specific business models.

Legal basis

The Re Gatecoin Ltd case establishes that cryptocurrencies can be used as trust assets.

Asset segregation

Customer assets are strictly separated from platform assets, and bankruptcy remoteness is provided.

Regulatory approval

SFC explicitly accepts TCSP-licensed entities as custodians.

TCSP License and VA Account Opening

Hong Kong banks have extremely strict scrutiny of account openings for virtual asset businesses. TCSP license holders, regulated by the Companies Registry, possess standardized CDD and record-keeping processes, meeting banks' compliance requirements. The trust model provides a clear asset segregation mechanism, reducing banks' concerns about money laundering or misuse of funds.

Typical scenarios

OTC customers deposit Hong Kong dollars into the VA account of a TCSP licensee → the licensee holds the funds in a trust arrangement → virtual assets (such as USDT) are transferred to the customer's wallet.

"TCSP first, VASP later" market strategy

Due to the high application threshold for VASP licenses (18-27 months review period, HKD 500 million share capital, HKD 300 million working capital), some OTC service providers choose to obtain a TCSP license first, operate custody services through a trust model, quickly obtain bank VA accounts, and then start their business. They then apply for a VASP license to cover transaction activities.

Phase 1: TCSP License

  • Obtain a license in 6-10 months
  • Open a VA bank account
  • Develop OTC hosting services
  • Establish compliance records

Phase Two: VASP Licensing

  • Application period: 18-27 months
  • Expanding trading platform business
  • Integrating custody and trading
  • Complete business closed loop

Challenge: Even when operating under a trust model, banks may still refuse to open accounts due to the high-risk nature of virtual assets. TCSP licensees need to prepare detailed compliance documentation (such as AML/CTF policies and transaction records) to increase their success rate.

FAQs

Quickly answer your most pressing questions

The key difference lies in the ability to directly act as trustee. A TCSP license allows you to appoint someone else as trustee, but you cannot directly manage trust assets yourself. A registered trust company, on the other hand, allows you to directly act as trustee and manage clients' trust assets. Furthermore, trust company registration has a HK$450 million financial threshold (HK$300 million in share capital + HK$150 million in collateral), while a TCSP license has no minimum capital requirement.

Yes. A company can hold both a TCSP license and a trust company registration simultaneously, allowing it to offer the most comprehensive services. Many companies adopt a 'TCSP first, trust later' strategy, starting their business with lower barriers to entry and then applying for trust company registration as their business grows.

通常需要6-8個月。包括3-4個月前期準備、2-3個月審核與面試、以及後續的核准流程。具體時間取決於申請資料的完整性和公司註冊處的工作量。

Registering a trust company requires a subscribed capital of HK$300 million and a guarantee of HK$150 million (which can be a bank guarantee or professional liability insurance). This is a strict financial threshold, reflecting the regulatory authorities' requirements for the financial soundness of trust companies.

 

Yes. A TCSP license allows a VASP platform to provide custody services by appointing a third party as trustee. According to SFC regulations, if a VASP holds client assets in trust through a subsidiary, that subsidiary must hold a TCSP license. If the VASP needs to directly manage the virtual asset trust, trust company registration is required.

A TCSP license is one of the key requirements for opening a VA account, but it does not guarantee success. Banks will still review the business model, AML/CTF policies, transaction records, etc. TCSP licensees are more likely to gain bank approval than unlicensed companies due to their regulation and standardized compliance processes, but they still need to prepare detailed compliance documentation.

Acquisitions typically take 3-4 months, saving 3-4 months compared to applying for a new application. A more significant advantage is the immediate access to an existing customer base, established banking relationships, and operational teams, enabling immediate operation. However, acquisition costs vary depending on factors such as the target company's customer base and business scale, requiring comprehensive due diligence.

The annual compliance requirements for both are similar: 1) Annual license/renewal fee (TCSP from approximately HK$2,910, trust companies from approximately HK$5,200); 2) Maintain AML/CTF compliance and regularly update policies and training; 3) Report material changes to the Companies Registry in a timely manner; 4) Maintain complete client due diligence and registration records; 5) Trust companies subject to investigation also need to maintain a financial requirement of HK$150 million.

About Aiying

Aiying (License.aiying.cc) specializes in global traditional finance and Web3-related license application and acquisition consulting services. With teams primarily located in Hong Kong, the UAE, and Europe, and strong relationships with local regulators, Aiying has successfully secured applications and smooth operations for leading and mid-tier crypto and traditional institutions. Team members are qualified in Hong Kong, Europe (Ireland), the UK, the UAE, and other jurisdictions, with a global network ensuring XNUMX/XNUMX professional support. Headquartered in Asia, the team brings together experts in operations, marketing, law, regulatory compliance, and accounting, adhering to clients' business objectives to provide comprehensive and in-depth strategies and solutions.

 

Authoritative guidance

Based on SFC official guidelines and Aiying's practical experience, we provide the most authoritative application guidance.

Useful Checklist

Detailed self-checklist and document preparation guide to ensure the completeness and accuracy of application materials

success case

100+ successful case experience summary, avoid common pitfalls and improve success rate

global vision

Integrate international best practices to ensure the forward-looking and adaptable compliance system

Aiying's "pre-screening mechanism"

To maximize your success rate, Aiying conducts an internal mock review of your application materials before formal submission. Our expert team acts as a regulator, scrutinizing each document from the most rigorous perspective to identify logical loopholes, data inconsistencies, and compliance gaps in advance.

Through this mechanism, we can ensure that the materials submitted to the regulatory authorities are highly professional, complete and impeccable, thereby minimizing the number of regulatory inquiries and significantly shortening the approval time.And reduced the license rejection rate by 67%.