ECSH52075 - Professional Body Supervision for Trust or Company Service Providers
Source: gov.uk (2025-10-27)


The 22 Professional Bodies(PBs) which act as Professional Body Supervisors (PBSs) are listed in Schedule 1 of The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017).

These PBs offer affiliation and professional membership to those working in the accountancy or legal sectors. The majority of UK TCSPs are accounting and legal professional members and are therefore supervised by the PBSs.

HMRC’s supervised TCSP population is smaller and consists of those without PBS or Financial Conduct Authority (FCA) supervision. HMRC supervises around 6% of all UK TCSPs.

For more information on professional body supervision of Accountancy Service Providers (ASPs) see ECSH52575 (https://www.gov.uk/hmrc-internal-manuals/economic-crime-supervision-handbook/ecsh52575).

Professional membership with a PB can help those working in accountancy or legal related roles demonstrate that they meet nationally or globally recognised professional and ethical standards set out by the PB. This is usually done by training, passing qualifying examinations and undertaking practical work experience, before being accepted as a member and undertaking continued professional development (CPD).

Professional membership with some of the PBs automatically includes anti-money laundering (AML) supervision. However this is not the case for all PBs and supervision should not be assumed as included in membership. Some PBs require a separate registration for a member to also be AML supervised by them and may charge a further fee for this. Not all PB members will pay for AML supervision by their PB, so some PB members are supervised by HMRC for AML purposes.

Some of the PBSs will supervise a TCSP business for AML purposes, and some PBSs will instead supervise the individual partners and principals who exercise control in a TCSP business. The partners/principals of the TCSP business may apply for AML supervision with a PBS as individuals, the TCSP business itself may apply for AML supervision with a PBS, or both the individuals and the TCSP business may apply. Each PBS has its own approach to how it manages this registration.

HMRC does not register individuals who carry out TCSP activity (unless they are a sole proprietor of a business offering TCSP services). Rather, HMRC registers the TCSP business. In order to register the business, however, HMRC must first determine whether all the beneficial owners, officers and managers are fit and proper persons. A TCSP must ensure that it is supervised for AML purposes t before it starts providing TCSP services.

Additional information on fit & proper checks can be found at ECSH45000 (https://www.gov.uk/hmrc-internal-manuals/economic-crime-supervision-handbook/ecsh45000).

Additional information on AML registration requirements can be found at ECSH40000 (https://www.gov.uk/hmrc-internal-manuals/economic-crime-supervision-handbook/ecsh40000).

If a TCSP is not supervised by a PBS or the FCA, it must apply to HMRC for supervision.

When PBSs cannot agree who the appropriate supervisor should be, again the TCSP must apply to HMRC for supervision. This could be the case for example where a TCSP business has several partners or principals, each holding their own professional membership with different PBs, or they are members of a PB that is not listed in Schedule 1 MLR 2017.

Unlike other professions such as doctors or solicitors, where it is only possible to practice after gaining a recognised qualification, anybody can set up in practice and call themselves a TCSP. The same is true for accountants. The TCSP profession therefore consists of qualified and unqualified accountancy professionals or legal practitioners who may also provide TCSP services, as well as those only offering TCSP services.

HMRC’s supervised TCSP population mostly consists of those who offer TCSP services without qualified accountancy or legal practitioner status. It also includes former members of PBs, such as those who have qualified and allowed their PB membership to lapse whilst remaining in practice.

Although unqualified, a substantial proportion will have participated in accountancy or legal training. Many unqualified practitioners in accountancy or legal roles are therefore highly competent to perform accountancy or legal work and view themselves as professionals. The HMRC supervised population therefore includes persons with a range of knowledge, experience and capability within the sector.

TCSP register

Regulation 54(2)(c) MLR 2017 requires HMRC to maintain a register of all relevant persons in the UK (except for those that are registered with the FCA) that act as a TCSP (the ‘TCSP Register’).

In order to comply with HMRC’s obligation to maintain the TCSP Register, HMRC requests that the PBSs notify HMRC of all relevant persons they supervise that carry out TCSP activity.

Whilst HMRC publishes externally a list of all relevant persons registered with HMRC for AML supervision, this only includes TCSPs registered directly with HMRC and does not include those on the TCSP Register.

The TCSP Register is not published online - it is held and managed centrally by HMRC.

(This content has been withheld because of exemptions in the Freedom of Information Act 2000)