TCSP services/HMRC TCSP register

The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017) require HMRC to maintain a register of all relevant persons who are trust or company services providers (TCSPs) that are not already registered with the FCA. 

Firms (including sole practitioners) which are TCSPs and are not on the register may be subject to disciplinary action by the IFA and/or criminal or civil penalties by HMRC.

In order to maintain the TCSP register, HMRC has requested the IFA (along with the other professional body supervisors) to notify HMRC of all the firms (including sole practitioners) that we supervise which perform TCSP work.  

The IFA will be adding relevant firm details to HMRC’s TCSP register from information included in your latest annual firm return. The details provided to HMRC are:

  • name and registered address of the firm; and
  • IFA confirmation that the firm is 'fit and proper’. 

The information included in the HMRC TCSP register will be made accessible to law enforcement agencies, UK or overseas supervisors and other authorities to the extent permitted under the Money Laundering Regulations. 

Please note that if the IFA is your AML supervisor, you don’t need to register separately with HMRC. The IFA will pass your details to HMRC as they must maintain the TCSP register.

What is TCSP work?

Under the MLR 2017, a trust or company service provider (TCSP) is any firm or sole practitioner whose business is to: 

  • form companies or other legal persons
  • act, or arrange for another person to act, as a director or secretary of a company
  • act, or arrange for another person to act, as a partner (or in a similar position) for other legal persons
  • provide a registered office, business address, correspondence address or administrative address for a company, partnership, or other legal person or arrangement
  • act, or arrange for another person to act, as a trustee of an express trust or similar legal arrangement
  • act, or arrange for another person to act, as a nominee shareholder for another person, unless the other person is a company listed on a regulated market which is subject to acceptable disclosure requirements.

A person is still considered to be a TCSP provider even if these services are provided incidentally to other accountancy services, or they are provided infrequently or on a one-off basis. 

Further information on HMRC’s definition of TCSP is available on HMRC’s website.

Updates to HMRC’s TCSP Register 

If the firm has answered 'no' to TCSP work in the latest annual firm return and the firms now wants to provide TCSP services, please email compliance@ifa.org.uk with your firm name and firm number and the IFA will forward the relevant information to HMRC to update their TCSP register.

If you no longer want to be included in HMRC’s TCSP Register, please email compliance@ifa.org.uk