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HMRC internal manual

Money Laundering Regulations: Registration

Trust or Company Service Providers (TCSPs): Businesses that are not TCSPs

What businesses will not be Trust or Company Service Providers?

Some officers of companies or partners of partnerships:

  • Individuals providing their services as company director, company secretary or partner provided they are not specified in MLR2R7350;


  • Any individual providing company director, company secretary or partner services to:

    • a firm already supervised under the MLR 2007, or
    • a public authority, or
    • a firm authorised by a public authority to act on their behalf where the only customers are public authorities

Some Trustees

  • Sole practitioners and firms who only provide professional trustee services limited to the following low risk trusts;

    • Straightforward express testamentary trusts such as those creating life interests for spouses or partners, trusts for persons under 25, dependents or persons under a disability or those that make provision for a charity
    • Express lifetime trusts created to manage the affairs of a person under a disability;
    • Occupational pension schemes and employee share schemes with no discretionary trusts

Recruiters and employment agencies

  • Firms and sole practitioners that only offer to their clients, in relation to the appointment of persons to act as a company director, company secretary, partner or professional trustee, the normal business services of employment agencies and employment businesses including the activities of;

    • Advertising for, headhunting or otherwise searching for suitable candidates for these positions (whether permanent or temporary)
    • The analysis of applications by such candidates and referring CVs to potential employers
    • Conducting preliminary and other interviews of such candidates
    • Checking qualifications or references of such candidates
    • Drawing up short lists of such candidates and making recommendations to clients about such candidates which stop short of actually selecting the final candidate
    • Supplying employers with a company director, company secretary, partner or professional trustee, (including temporary ones) so long as the employment agency or business does not itself provide for a person’s appointment to a relevant position in the way described in the “Arranging” Section. See MLR2R7100.