TCSP: the product is the structure

Trust and company service providers sit in an unusual position: the sector's everyday product — companies, trusts, multi-jurisdiction structures — is the same machinery that can be used to distance a person from their assets. That is why the EU risk assessment and FATF guidance rate company- and trust-formation services as high-risk, and why, with Cyprus's large corporate-services sector, robust due diligence by TCSPs is a national priority reflected in MOKAS and supervisory guidance.

The red flags are structural rather than exotic: complex structures with no clear commercial rationale; reluctance to disclose the ultimate beneficial owner; nominee directors and shareholders layered across jurisdictions; connections to higher-risk jurisdictions or PEPs.

The obligations follow: identify and verify beneficial owners, understand the purpose of the structure, screen every party, and apply enhanced due diligence where complexity or jurisdiction raises risk.

The full sector assessment — the rating, the red flags, the expected controls — is published with its methodology: firm.cy/aml-sector/trust-company-service-providers

Not legal advice. Verify against the primary source before acting.

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