Trust & Company Service Providers

In the UK, Trust & Company Service Providers (TCSPs) are subject to the Money Laundering Regulations and are supervised for AML purposes based on their activities. Most TCSPs are currently supervised by HM Revenue & Customs (HMRC), which oversees AML compliance for corporate, trust and fiduciary services.

However, the regulatory landscape is evolving. The UK Government has confirmed reforms that will see AML supervision for professional services firms, including TCSPs, transition to the Financial Conduct Authority. Under the new regime, TCSPs will be required to register directly with the FCA for AML supervision. This will entail obtaining FCA user credentials, registering the business and the relevant senior responsible individuals (including the MLRO/AML lead), and undergoing a structured application process aligned to strict AML standards.

Under FCA-led supervision, TCSPs will be expected to demonstrate that their AML frameworks are robust, proportionate, effective and evidenced in practice. Specifically, the FCA will expect TCSPs to be able to demonstrate that they have:

• A firm-wide risk assessment that accurately reflects the nature, scale and complexity of their services and client relationships
• Clear and tailored AML policies, controls and procedures that are embedded into daily operations
• Strong governance, oversight and accountability, with clearly defined AML roles and responsibilities
• Effective customer due diligence (CDD) and enhanced due diligence (EDD), including Customer Risk Assessments,  beneficial ownership, source of funds/wealth, PEPs and sanctions screening
• Appropriate ongoing monitoring and periodic review of client activity and risk levels
• Comprehensive training for all relevant staff, aligned to TCSP-specific risks
• Well-maintained audit trails and evidence demonstrating how AML decisions are made, challenged, documented and escalated

The FCA places particular emphasis on evidence, governance and outcome-focused supervision, meaning firms must be able to demonstrate how controls operate, not just that they exist.beneficial to write those down beforehand so that you don't forget to ask them during your meeting.

The AML Practice supports TCSPs at every stage of the AML compliance lifecycle, combining deep regulatory insight with practical, proportionate implementation. We help firms:

• Prepare for and navigate FCA registration and supervisory engagement, including system access, documentation and regulatory correspondence
• Undertake AML gap analysis and independent reviews, identifying weaknesses in design or execution and providing clear remediation actions
• Develop and enhance AML policies, controls and procedures tailored to TCSP risk profiles
• Conduct AML audits focused on both design and operational effectiveness, with reports suitable for internal governance and supervisory review
• Deliver sector-specific AML training for directors, compliance leads and operations staff
• Provide ongoing AML support, including ad-hoc advisory, EDD assistance, policy refreshes, attestation support and updates on regulatory developments

Our focus is on practical, defendable and regulator-ready AML frameworks that help TCSPs meet current expectations and thrive under the incoming FCA-led regime.