About TCSP

The TCSP license is a special type of license issued by the Hong Kong Companies Registry exclusively for qualified corporate bodies or individuals after fulfilling the prescribed standard of practice and assessment.

The TCSP licensing regime is in line with international requirements as promulgated by the Financial Action Task Force (FATF). This initiative safeguards the integrity of Hong Kong as an international financial centre and adds confidence and credibility for companies doing business in the City.
Every TSCP licensee should comply with the following requirements:

1) Customer Due Diligence:

Customer Due Diligence (CDD) measures are intended to enable a TCSP licensee to form a reasonable belief that it knows the true identity of each customer and, with an appropriate degree of confidence, knows the type of business and transactions the customer is likely to undertake. Depending on specific circumstances, TCSP licensees may also need to conduct additional measures (referred to as enhanced customer due diligence or, alternatively, may conduct simplified customer due diligence.

The purposes of Customer Due Diligence (CDD) measures are:

· To know the customer and understand the customer’s business;
· To protect company’s staff from committing offences under the anti-money laundering and combating the financing of terrorism (Anti-Money Laundering/ Terrorist Financing Compliance) legislation;
· To comply with obligations under the Anti-Money Laundering/ Terrorist Financing Compliance legislation; and
· To minimise risks of being inadvertently exploited by criminals in their money laundering and financing of terrorism schemes.

2) Ongoing monitoring:

Governed by the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (AMLO), the business relationship between TCSPs and their customers has to be continuously monitored. This includes the regular review of ownership structures, monitoring transactions of the customers and identifying transactions that are complex, large and unusual. Under certain circumstances (such as customers not being physically present for identification purposes and other high-risk situations), the AMLO would warrant enhanced due diligence requirements and impose additional measures.

3) Record-keeping:

To ensure TCSPs are meeting the compliance standards, the Hong Kong Companies Registry conducts regular site inspections, desktop reviews and face-to-face interviews with the TCSP licensees. Any non-compliant TCSPs would be subject to warnings, disciplinary actions, suspension or revocation, non-renewal of license or (in serious cases) prosecution.

Our company Sino Secretary Limited is TCSP license holder (TC 0007484), meets all the requirements of the Hong Kong Companies Registry for Anti-Money Laundering and Terrorist Financing Compliance for Trust Companies or Company Service Providers.
To fulfil the above-mentioned obligations, Sino Secretary Limited as a TCSP license holder assess the Money Laundering/ Terrorist Financing risk of the businesses, develop and implement policies, procedures and controls on:

(a) risk assessment;
(b) customer due diligence (“CDD”) measures;
(c) ongoing monitoring of customers;
(d) suspicious transactions reporting;
(e) record keeping; and
(f) staff training.

Our employees are regularly trained to maintain TCSP licensee’s policies and procedures in relation to prevent any Risk of Money laundering as well complying with other ongoing obligations of a TCSP licensee, including the statutory requirements relating to customer due diligence and record-keeping. Also, our employees are aware of any new and emerging techniques, methods and trends in Money laundering/ Terrorist financing to the extent that such information is needed to carry out their respective roles with respect to AML/CTF.