What is a TCSP AML independent review?
A TCSP AML independent review assesses whether a Hong Kong trust or company service provider has adequate AML/CFT policies, procedures and controls, and whether those controls are operating effectively in practice.
The review typically covers risk assessment, customer due diligence, screening, ongoing monitoring, suspicious transaction reporting, record keeping, staff training, employee screening and related internal controls.
Who this service is for
- Hong Kong TCSP licensees requiring an independent AML/CFT review report.
- Company secretarial firms providing incorporation, maintenance, registered office or nominee-related services.
- Small to mid-sized TCSPs that want a structured but practical review process.
- TCSPs with outdated policies, inconsistent forms or incomplete risk assessment records.
What areas are reviewed?
The review is scoped to the client’s business model and risk profile. Common review areas include AML/CFT governance, institutional and customer risk assessment, CDD, EDD, beneficial ownership documentation, customer screening, ongoing monitoring, STR procedures, record keeping, staff training and employee screening.
What is included in the report?
The independent review report is the core deliverable. It is not a low-tier or high-tier product. The report covers the agreed review scope, key observations, findings and recommendations. Add-on services relate to policy manuals, forms, risk assessment documents, staff training or implementation support outside the report.
Risk-based client file review
Where relevant, selected client files and compliance records are reviewed on a risk-based basis. This may include ordinary-risk customers, higher-risk customers, corporate customers, beneficial ownership records, PEP or EDD cases and other relevant records.
Typical process
- Short intake and scope confirmation.
- Indicative fee and engagement arrangement.
- Document request and file selection.
- Review of policy, records and selected customer files.
- Findings discussion where appropriate.
- Final AML/CFT Independent Review Report.
- Optional documentation or implementation support.
Timeline and fee approach
A standard review can often be completed within two to four weeks, subject to document readiness, client responsiveness and the agreed scope. Fees depend on active client number, service types, risk profile, document readiness, timeline urgency and whether add-ons are required.