ECSH52300 - Trust or Company Service Providers (TCSPs) providing Accountancy Service Providers (ASPs)or other supervised sector services
Source: gov.uk (2025-10-28)


It is not unusual for a TCSP to provide services which would fall within the definition of an ASP. In such cases the business is acting as both a TCSP and an ASP and its registration must reflect this, as must its compliance with The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017).

Where a TCSP is also conducting relevant ASP activity, you should also refer to section ECSH52500 (https://www.gov.uk/hmrc-internal-manuals/economic-crime-supervision-handbook/ecsh52500).

A TCSP which also acts as an ASP, will usually provide a registered office address service. This TCSP service enables an ASP to receive its customers’ formal communications from HMRC and/or Companies House, and assist the ASP with making sure its customers meet obligations to file confirmation statements, tax returns and so on. Generally, the TCSP/ASP offering this combination of services will not receive commercial correspondence on behalf of its customers’ trading activities.

An ASP might also act as a TCSP by forming firms for an existing customer or providing a standalone company formation service to new customers wishing to set up or incorporate their business.

There are TCSP businesses that conduct relevant activity under MLR 2017 other than (and/or in addition to) that of an ASP. This includes some Estate Agency Businesses (EABs) and a small number of Money Service Businesses (MSBs) where their business model includes TCSP activity.

In all cases, the business's registration for anti-money launderingML supervision must describe of the relevant activity the business conducts and it must adhere to all of its obligations under MLR 2017.

At a compliance visit, an officer should seek to understand all TCSP and ASP services (relevant activity) conducted by the TCSP/ASP, how the TCSP/ASP has risk assessed each service alone and in combination, and how it manages and mitigates those risks.

Record testing should span all of the ASP and TCSP services provided. For example, where a TCSP provides firm formations, bookkeeping, payroll services, records should be selected where firm formations have been provided, bookkeeping services have been provided, where payroll services have been provided, and where combinations of those services have been provided together.

Where the TCSP/ASP also carries out relevant activity in another supervised sector, an officer should seek to understand the business’s compliance with MLR 2017 in respect of that additional sector(s). Record testing should span all sectors of relevant services provided by the business, including where provided in combination.

General money laundering, terrorist financing and proliferation financing risks for TCSPs can be found at ECSH52125 (https://www.gov.uk/hmrc-internal-manuals/economic-crime-supervision-handbook/ecsh52125) and general risks for ASPs can be found at ECSH52625 (https://www.gov.uk/hmrc-internal-manuals/economic-crime-supervision-handbook/ecsh52625). At a compliance visit, TCSPs providing ASP services should be expected to provide an explanation for any departure from published guidance.

You should also refer to the section of the handbook relevant to:
- TCSPs who are multiple-service providers at ECSH52275. (https://www.gov.uk/hmrc-internal-manuals/economic-crime-supervision-handbook/ecsh52275)
any other sector where the business is conducting relevant activity at ECSH50000. (https://www.gov.uk/hmrc-internal-manuals/economic-crime-supervision-handbook/ecsh50000)