Risk-based Approach for Trust and Company Service Providers | FATF

door Ellen Timmer, advocaat ondernemingsrecht @Pellicaan

On 26 June 2019 FATF published the new version of their Risk-based Approach for Trust and Company Service Providers. The announcement is to be found here.

Trust and company service providers (TCSPs) in the glossary are described as follows:

Trust and Company Service Providers refers to all persons or businesses that are not covered elsewhere under the Recommendations, and which as a business, provide any of the following services to third parties:

  • Acting as a formation agent of legal persons;
  • Acting as (or arranging for another person to act as) a director or secretary of a company, a partner of a partnership, or a similar position in relation to other legal persons;
  • Providing a registered office; business address or accommodation, correspondence or administrative address for a company, a partnership or any other legal person or arrangement;
  • Acting as (or arranging for another person to act as) a trustee of an express trust or performing the equivalent function for another form of legal arrangement;
  • Acting as (or arranging for another person to act as) a nominee shareholder for another person.


Interestingly this definition includes accomodation providers, without explaining the term. It could include everyone leasing/letting commercial property, not only parties that provide a correspondence address to ‘houseplant‘ companies, that so now and then want to rente a conference room.

The guidance is aimed at both the TCPSs, the authorities and at practitioners that have TCSPs as customers.

This time FATF claims to have consulted the TCPSs in regard to this guidance, “to ensure that it reflects their practical expertise and good practices“.

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