Companies Registry Updates TCSP Guidelines

Companies Registry Updates TCSP Guidelines

Revised CR guidelines reduce the CDD verification timeline to 30 days and mandate biennial Institutional Risk Assessments.

In early 2025, the Companies Registry issued a comprehensive update to the “Guideline on Compliance of Anti-Money Laundering and Counter-Terrorist Financing Requirements for Trust or Company Service Provider (TCSP) Licensees”. The revised text introduces significant operational hurdles designed to eliminate delays in customer vetting and address institutional vulnerabilities.

A critical procedural amendment is the reduction of the identity verification timeline under Customer Due Diligence (CDD). The allowable timeframe for completing customer verification has been cut from 60 days to within 30 days of establishing a business relationship, compelling TCSPs to accelerate their onboarding screening procedures.

In addition, the updated guidelines formalize the distinction between Institutional Risk Assessments (IRA) and Customer Risk Assessments (CRA). TCSPs are required to document a holistic IRA evaluating customer segments, service complexity, delivery channels, and internal control resources. Licensees must formally review and update their IRA at least every two years, or immediately upon material trigger events such as business reorganizations or new service launches.

For TCSP compliance teams, passive compliance is no longer viable. Regulators are actively inspecting whether firms maintain independent audit functions, periodic staff training, and documented proof that senior management routinely reviews and approves institutional risk profiles.