Concept
A trust and company service provider (TCSP) licence is a regulator's permission to provide, by way of business and to other people, the services on which a private structure rests: forming companies, supplying a registered office and address, acting as director or secretary of a client's company, holding its shares on the client's behalf, and acting as trustee of the client's trust. In Hong Kong, Singapore, Jersey, Guernsey, the BVI, Cayman, Malta and Cyprus that work requires the regulator's permission.
The regime exists because the provider stands at the entrance to every structure: company formation, the appointment of directors and the registration of shareholders all pass through it. Singapore's registrar, ACRA, explained its 2024 reform by pointing out that providers outside the registration net could be engaged to facilitate illicit activity, and that shell companies used for money laundering were largely set up by providers appointing unqualified individuals as directors (ACRA on the Corporate Service Providers Act 2024).
A TCSP licence therefore first makes the provider answerable for vetting its clients, and only then becomes a product it can sell.
One regime or two
Jurisdictions divide this market differently. Hong Kong, Jersey, Guernsey and Cyprus grant a single permission covering corporate and trust services together. Singapore, Malta and Cayman split them between different statutes, and Singapore also between different authorities: ACRA registers corporate service providers while the Monetary Authority of Singapore (MAS) licenses trust business. The BVI keeps both services in one statute but in different licence classes.
Key parameters
For split regimes the table shows the trust permission.
| Jurisdiction | Regulator and statute | Minimum capital | Staffing requirements |
|---|---|---|---|
| Hong Kong | Registrar of Companies; AMLO (Cap. 615), Part 5A | None for the TCSP licence; voluntary trust company registration — HK$3 000 000 | No headcount requirement |
| Singapore | ACRA (CSP Act 2024) and MAS (Trust Companies Act 2005) | Trust company: S$250 000 | At least 2 resident managers |
| Jersey | JFSC; Financial Services (Jersey) Law 1998 | £25 000; £5 000 for certain narrow classes | At least 3 individuals full time where the provider controls client assets |
| Guernsey | GFSC; Fiduciaries Law 2020 | £25 000 | At least 2 directing individuals (four-eyes test) |
| BVI | FSC; Banks and Trust Companies Act 1990, Company Management Act 1990 | US$250 000 plus a deposit with the FSC | Undertaking to establish physical presence within 2 years |
| Cayman | CIMA; Banks and Trust Companies Act, Companies Management Act | CI$400 000 net worth | 2 directors actively engaged in the business |
| Malta | MFSA; Trusts and Trustees Act (Cap. 331), CSP Act (Cap. 529) | Trustee: €15 000; Class C provider: €25 000 | Trustee: at least 3 directors |
| Cyprus | CySEC; Law 196(I)/2012 | Not set in the Law | Head office in Cyprus, at least 2 managers |
Capital varies several-fold, yet most of the cost usually lies in the staff a regulator expects and in professional indemnity cover.
How a provider fits into a structure
A typical private structure passes through several licences at once. Below is a family trust under Jersey law that owns a BVI holding company.
The trustee is a company registered with the Jersey Financial Services Commission for the class covering trustees of express trusts. The BVI holding company is serviced by a registered agent licensed by the BVI Financial Services Commission. If the provider also supplies the holding company's director, that is another licensed service. Each of the three providers answers to its own regulator for vetting the settlor and the source of funds. The roles of trustee and protector are covered in Trustee and Protector; the choice of trust law in Trust Jurisdictions: A Map for Choosing Where to Settle.
What sets the regimes apart
The eight regimes diverge along three lines, and each changes who pays how much for the licence.
Who is exempt
Hong Kong exempts banks, SFC licensees, accountants and lawyers; in Cyprus lawyers and accountants work under their own professional bodies. A law firm often needs no separate licence.
How many people are needed
Jersey requires three people full time where the provider controls client assets, Singapore two resident managers, Cayman and Cyprus two managers, a Maltese trustee company three directors. Hong Kong sets no headcount.
Insurance
Jersey and the BVI require a trust company policy of at least £5m and US$5m. Guernsey requires from £1m, a Maltese corporate service provider from €1m per claim, Singapore cover commensurate with risk.
Hong Kong and Singapore
Hong Kong: the TCSP licence and trust company status
The TCSP licence is granted by the Registrar of Companies under the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615). It is required by anyone who, by way of business in Hong Kong, forms companies, acts as or arranges a director, secretary or partner, provides a registered office or address, acts as trustee of an express trust, or acts as shareholder on another person's behalf (a nominee shareholder, in the statutory wording) in an unlisted company (Registrar's guideline, May 2025).
Alongside the licence there is voluntary registration as a trust company under Part 8 of the Trustee Ordinance (Cap. 29). The two are different statuses: the licence permits the business, while registration gives the company the status of a registered trust company and requires capital (Registrar's pamphlet on the licence, pamphlet on trust company registration).
| Parameter | TCSP licence (AMLO) | Trust company (Trustee Ordinance, Part 8) |
|---|---|---|
| Mandatory | Yes, for trust and company services by way of business | Voluntary |
| Capital | None set | Paid-up capital from HK$3 000 000; deposit from HK$1 500 000 |
| Owners and people | Fit and proper for directors, partners and owners of more than 25%; changes need the Registrar's approval | Non-private company, at least 2 directors |
| Fees | HK$3 440 plus HK$975 per person vetted; licence for 3 years | HK$11 250 plus HK$840 for the certificate |
| Acting without permission | Fine up to HK$100 000 and up to 6 months' imprisonment | — |
The entry threshold for a TCSP licensee is therefore set by the reputation of owners and managers; capital comes into play only if the company wants registered trust company status. Renewal of the licence is filed at least 60 days before expiry. The corporate side is covered in Hong Kong Company: Incorporation, Taxation, Banking.
Singapore: ACRA registration and an MAS licence
Since 9 June 2025 the Corporate Service Providers Act 2024 has required anyone carrying on a business of providing corporate services in or from Singapore to register with ACRA. The Act covers forming companies, acting as directors, secretaries and partners, providing an address, acting as shareholder on another person's behalf, certain client transactions in the course of accounting services, and filing with ACRA for others.
Registration costs S$400 for two years per provider and S$200 per registered qualified individual (RQI). Operating unregistered carries a fine of up to S$50 000 or up to two years' imprisonment; breaching AML rules carries a fine of up to S$100 000 per breach for both the provider and its senior management.
The Act adds a specific rule for directors who act on a client's instructions (nominee directors, in the Act's wording): a person may take such a role by way of business only if the appointment is arranged by a registered provider, and the provider must itself be satisfied that the person is fit and proper. The fine is up to S$10 000 for the director and up to S$100 000 for the provider.
Trust business falls outside that Act. Only a licensed trust company may carry on trust business in or from Singapore (s. 3 Trust Companies Act 2005); a breach carries a fine of up to S$75 000 or imprisonment of up to three years.
| MAS requirement | Value |
|---|---|
| Paid-up capital at grant | S$250 000; for a foreign company, qualifying assets of the same amount |
| Net assets after year one | At least the higher of ¼ of annual expenditure and ¾ of minimum capital |
| Professional indemnity insurance | Mandatory, commensurate with business risk |
| People | At least 2 resident managers |
| Fees | S$1 000 per application, S$4 000 a year |
The requirements are set out in the Trust Companies Regulations. A provider that forms clients' companies and wants to act as trustee of their trusts goes through both regimes: ACRA registration and MAS licensing. More on trust structures in Trust Structuring in Singapore, on the company in Singapore Company.
Jersey and Guernsey
Jersey: registration by class
In Jersey, trust and corporate work is called trust company business and requires registration with the Jersey Financial Services Commission (JFSC) under Article 9 of the Financial Services (Jersey) Law 1998. Registration is granted by class: company formation, directors, partners, secretaries, registered office, address, trustee of an express trust, shareholder on another's behalf, foundation council member. The Trust Company Business Code of Practice, in force since 1 June 2019, sets the financial and staffing requirements.
| JFSC requirement | Full registration | Narrow classes |
|---|---|---|
| Capital and net assets | £25 000 | £5 000 |
| Liquid assets | 110% of the expenditure requirement | Per the Code |
| Professional indemnity | Greater of 3× fees, 30× fees from the largest client and £5m; cap £10m | £1m or £2m |
| Management | At least 3 individuals full time where the provider controls client assets | "Four eyes" or "two eyes" |
The Code treats as narrow the classes in which the provider only forms companies, acts as secretary or supplies an address. Close family members count as only one person in the management, and the compliance officer is directly employed and based in Jersey.
Guernsey: the fiduciary licence
In Guernsey the same business is licensed by the Guernsey Financial Services Commission (GFSC) under the Fiduciaries Law 2020; licences are primary, secondary or personal. The GFSC rules require paid-up capital of at least £25 000, liquid assets of at least 25% of annual expenditure, and indemnity cover of at least the greater of three times turnover from regulated activities and £1m.
A primary or secondary licensee is directed by at least two individuals, and the GFSC expects Bailiwick-based senior executives in a number commensurate with the business. Trust law on both islands is covered in Jersey and Guernsey Trusts.
BVI and Cayman
BVI: classes of trust licence
The Banks and Trust Companies Act 1990 divides the trust licence into classes: Class I covers trust business and company management, Class II trust business only, Class III company management only. A restricted Class II licence allows only trusts listed in a sworn undertaking; a restricted Class III licence allows only the provision of directors, officers and shareholders acting on another's behalf to BVI companies (FSC licensing guidance). A separate company manager licence is granted under the Company Management Act 1990.
| Requirement | Classes I–III | Company manager |
|---|---|---|
| Capital | US$250 000, unencumbered | US$25 000 |
| Deposit with the FSC | Class II: US$20 000; Classes I and III: US$30 000 to US$80 000 by number of companies served | — |
| Professional indemnity | At least US$5m or a multiple of fees; cap US$10m | At least US$1m; cap US$2m |
Capital, deposit and insurance are set by the Regulatory Code (ss. 155–161). The FSC gives its decision time as 10 weeks for Classes I–III and 6 weeks for restricted classes. An applicant for an unrestricted licence undertakes to establish physical presence in the Territory within two years of grant (FSC on licence applications). The Class I application fee is US$1 000 and the annual fee US$16 000; for Classes II and III, US$14 000 and US$12 000. The company itself is covered in BVI Company.
Cayman: trust licence and companies management licence
In Cayman, the Cayman Islands Monetary Authority (CIMA) licenses trustees under the Banks and Trust Companies Act, and company management and corporate services under the Companies Management Act. The minimum net worth depends on the licence (CIMA net worth policy).
| Licence | Net worth |
|---|---|
| Trust | At least CI$400 000 |
| Restricted trust | At least CI$20 000 |
| Companies management | At least CI$25 000 |
| Corporate services | Generally at least CI$15 000 |
In its trust licence application requirements CIMA asks for evidence that two directors are actively engaged in the business, and for the auditor's confirmation that capital is paid up. The corporate side is covered in Cayman Islands Company.
Malta and Cyprus
Malta: trustee and corporate provider under separate statutes
Anyone in or from Malta who acts as trustee for remuneration, on a regular basis or holding themselves out as trustee needs authorisation from the Malta Financial Services Authority (MFSA) under Article 43 of the Trusts and Trustees Act. A trustee company keeps capital of at least €15 000, has at least three approved directors, holds insurance proportionate to its business and has every holder of 10% or more approved by the MFSA.
Corporate services are governed by the Company Service Providers Act (Cap. 529), from which an MFSA-authorised trustee is exempt (MFSA FAQs, May 2025). The MFSA rulebook for company service providers divides them into Classes A, B and C.
| Class | Services | Initial capital |
|---|---|---|
| A | Company formation, registered office and address | €10 000 |
| B | Director, secretary, partner | €15 000 plus insurance |
| C | All company service provider services | €25 000 plus insurance |
Individuals whose turnover or number of posts falls below the rulebook thresholds operate in Classes A and B with capital of €2 500 and €5 000. The indemnity limit is the higher of three times relevant income and €1m per claim (€1.5m in aggregate).
A corporate provider is directed by at least two individuals, and a foreign company keeps an office in Malta and at least one Malta-resident manager. Since 2025 an individual acting as director or secretary in no more than ten companies registers under a lighter regime as a Limited CSP, and someone holding such posts not by way of business notifies the MFSA within 14 days. The tax side of a Maltese holding is in Malta Holding.
Cyprus: the CySEC ASP licence
Under Law 196(I)/2012, trust administration, including acting as trustee, and company management services — directors, secretaries, holding shares for third parties, registered office, opening and operating bank accounts — may be provided only by companies licensed by the Cyprus Securities and Exchange Commission (CySEC) or by exempt lawyers and accountants supervised by the Cyprus Bar Association and the Institute of Certified Public Accountants of Cyprus (ICPAC).
The Law describes the licensee through its people and place of management and sets no minimum capital. The head office is in Cyprus, the company is managed by at least two persons of good repute and experience, CySEC approves the compliance officer, and a lawyer is employed in-house or on a standing engagement.
CySEC decides on a complete application within four months. Unlicensed business is a criminal offence carrying up to five years' imprisonment or a fine of up to €350 000; for breaches of the Law and AML rules CySEC imposes administrative fines of up to €500 000, or up to €1m for a repeat. The company as the base of a structure is covered in Cyprus Holding.
What changed in 2024–2025
Over two years the regimes tightened noticeably, and almost every change concerns the people who act as directors and trustees.
| Jurisdiction | Change | From |
|---|---|---|
| UK, Crown Dependencies and Overseas Territories | Ban on trust services to persons connected with Russia supplemented with a definition of acting as nominee shareholder | 05.12.2024 |
| Hong Kong | New Registrar guidelines on AML for TCSP licensees and on licensing | March and May 2025 |
| Singapore | ACRA registration for all corporate service providers; rules for directors acting on client instructions | 09.06.2025 |
| Malta | Limited CSP registration and MFSA notification for directors not acting by way of business | 2025 |
| Guernsey | Every PTC needs a licence or a limited permission | September 2025 |
The direction is the same everywhere: regulators no longer treat the role of director or trustee as "private" and require a vetted licensee behind every such appointment.
The private trust company exception
A family that wants to run its own trusts sets up a private trust company (PTC): it acts as trustee only for trusts of connected persons and offers no services to the public. Jurisdictions exempt it from the trust licence on different conditions, and almost everywhere a licensed professional must stand alongside it in return. A detailed comparison of regimes is in Private Trust Company (PTC).
| Jurisdiction | PTC status | Who stands alongside |
|---|---|---|
| Singapore | Exempt from licensing (reg. 4, Exemption Regulations) | A licensed trust company for the checks MAS rules require |
| Jersey | Exempt (Order 2000); Schedule 2 registration for AML supervision | A registered trust company business provider |
| Guernsey | Since September 2025, a licence or limited permission (GFSC guidance) | A licensed fiduciary as administrator |
| BVI | Exemption for unremunerated or related trust business (Exemptions Regulations 2007) | A registered agent holding a Class I licence |
| Cayman | Registration with CIMA instead of a licence (PTC Regulations) | Registered office with a trust licence holder |
The exemption rests on facts: a PTC that starts serving outsiders loses it and falls under the ordinary licensing regime.
Popular, but it ends badly
The most common grey practice is the "private" director or trustee who takes on client companies and trusts through personal connections, without a licence, assuming this is not business. Hong Kong and Singapore tie the licence to acting by way of business; Malta's trust statute ties it to remuneration, regularity or holding oneself out as trustee.
| Jurisdiction | Acting without permission |
|---|---|
| Hong Kong | Fine up to HK$100 000 and up to 6 months' imprisonment |
| Singapore | Provider: up to S$50 000 or up to 2 years; director on client instructions outside a provider: up to S$10 000; trust business: up to S$75 000 or up to 3 years |
| Malta | Trustee for remuneration or on a regular basis only with MFSA authorisation; even a director of one or two companies notifies the MFSA |
| Cyprus | Up to 5 years' imprisonment or a fine of up to €350 000 |
The second practice is to order a turnkey licence and keep the people on the island only on paper. Jersey counts in management only those working locally full time, the BVI takes an undertaking to establish physical presence within two years, and Cayman checks that two directors are actively engaged. Working under someone else's licence is possible, but the licensee remains responsible for it (see License for Rent), and buying a ready licensee requires approval of the new owners (see Change of Control and Buying a Licensed Company).
Sanctions perimeter for clients from Russia
For clients from Russia the map splits between two sanctions regimes, and their tests differ.
| Regime | Who is caught | Where it applies |
|---|---|---|
| EU, Article 5m | Russian nationals and residents, Russian entities and structures they own or control | Malta, Cyprus |
| UK, reg. 18C | Persons resident or located in Russia, Russian entities | Jersey, Guernsey, BVI, Cayman |
| Neither | — | Hong Kong, Singapore |
Providers in the EU, including Malta and Cyprus, are bound by Article 5m of Regulation (EU) 833/2014. They may not register a trust, provide it with an address or management services, or act as its trustee, nominee shareholder, director or secretary where the trustor or beneficiary is a Russian national or resident, an entity established in Russia, an entity more than 50% owned or controlled by such persons, or anyone acting on their behalf.
The Article 5m(4) exception covers only natural persons who are nationals of the EU, the EEA or Switzerland or hold a residence permit there. A national authority may authorise continued trustee services where the provider passes no funds or benefit from trust assets to those persons (Article 5m(5)(b)), and services for humanitarian purposes, pension and insurance schemes, charities and trusts for minors (Article 5m(6)).
Since 16 December 2022 the UK has prohibited trust services to or for the benefit of persons connected with Russia (reg. 18C, Russia (Sanctions) (EU Exit) Regulations 2019): creating a trust, providing an address, operating or managing it, acting as trustee, and since 5 December 2024 the rule also defines acting as nominee shareholder. Connection with Russia turns on ordinary residence or location, and for companies on incorporation or domicile; nationality is irrelevant. Arrangements in place immediately before 16 December 2022 may continue.
The UK regime applies in the BVI and Cayman through the Russia (Sanctions) (Overseas Territories) Order 2020, in Jersey through the 2021 Order on external sanctions, and in Guernsey through the 2020 Regulations implementing UK regimes; all three pick up UK amendments automatically.
Vetting of the provider's own owners is covered in Qualifying Holdings and Fit & Proper; structures for Russian capital in Sanctions-Resilient Structures in 2026.
How to choose between regimes
The choice starts with the services the provider offers. If it only forms companies and supplies an address, a light corporate regime is enough; if it will act as trustee, capital, insurance and staffing requirements rise several-fold. Next comes where clients hold their structures: registered agent services to BVI companies are provided by an FSC licensee, and the number of such companies determines its deposit.
| Business model | Regime | What decides |
|---|---|---|
| Forming and servicing companies for clients in Asia | Hong Kong (TCSP) or Singapore (ACRA) | Hong Kong: fit and proper test without capital requirements; Singapore: fee, qualified individuals and rules for directors |
| Trustee for Asian families | Singapore (MAS) | S$250 000, two resident managers, insurance |
| Trustee and full corporate service for European and international clients | Jersey or Guernsey | Modest capital; staff and cover of £1m to £5m are the real cost; closed to persons connected with Russia |
| Registered agent for BVI companies | BVI, Class I or III licence | US$250 000, deposit, presence in the Territory; UK sanctions regime |
| Trustee for funds and structures in Cayman | Cayman | Net worth CI$400 000, two directors; UK sanctions regime |
| Provider inside the EU | Malta or Cyprus | Malta: from €10 000 for Class A to €25 000 for Class C, trustee €15 000; Cyprus: no capital set by the Law; Article 5m prohibition |
| Offshore IBC formation outside the map | Seychelles (second league) | A licence under the International Corporate Service Providers Act 2003 covers both corporate and trustee services; the company itself in Seychelles IBC |
Common to every licensee are the compliance functions a regulator expects (see Compliance Stack for a Licensed Operator) and the requirements for real presence (see Substance: Economic Presence Requirements). Other financial licences are gathered in the Financial Licences hub.
Q/A
Licence and cost
Do I need a licence to act as director of several client companies?
If it is done by way of business, yes. In Hong Kong it is a licensed service, in Singapore such a director may be appointed only through a registered provider, and in Malta an individual with up to ten posts registers as a Limited CSP.
Where is a trust licence cheapest?
By capital, Hong Kong and Cyprus: the TCSP licence also covers acting as trustee with no capital floor, and the Cyprus Law sets no capital. Hong Kong's registered trust company status is voluntary and requires HK$3 000 000. Among regimes with mandatory capital, a Maltese trustee company is lowest (€15 000), followed by Jersey and Guernsey (£25 000), where the main costs are staff and insurance: from £1m in Guernsey and from £5m in Jersey.
How long does the regulator take?
The BVI FSC gives 10 weeks for Classes I–III and 6 for restricted classes. CySEC decides within four months of a complete application. A Hong Kong licence is granted for three years and renewed by an application filed at least 60 days before expiry.
People and presence
Can a Jersey registered person be run from abroad?
Not if the provider can control client assets: the JFSC Code then requires at least three individuals actively involved in day-to-day management full time and a compliance officer employed and based in Jersey. For narrow classes "four eyes" is accepted.
Is an office in the BVI required?
An applicant for an unrestricted trust licence undertakes to establish physical presence within two years of grant. Restricted Class II and III applicants are not required to give that undertaking.
Trusts, PTCs and sanctions
Does a family trust company need a licence?
Usually not, if it acts as trustee only for trusts of connected persons and offers no services to the public. In return jurisdictions require a licensed professional alongside it: in Singapore, a licensed trust company for client checks. Since September 2025 Guernsey has required a PTC to hold a licence or a limited permission.
Can a Russian resident set up a trust with a provider in one of the eight jurisdictions?
New trust services are closed to them in six jurisdictions: in Malta and Cyprus under Article 5m of Regulation 833/2014, in Jersey, Guernsey, the BVI and Cayman under reg. 18C of the UK regulations. Hong Kong and Singapore remain open, as neither prohibition applies there. A Russian national living in the EU, the EEA or Switzerland on a residence permit falls within the Article 5m(4) exception, and the UK ban does not reach them while they are neither resident nor located in Russia.