Definition
A Trust or Company Service Provider (TCSP) is a business that forms companies, provides registered offices, acts as or arranges directors, trustees or nominee shareholders, or provides similar corporate and trust services. In Ireland, TCSPs are designated persons supervised for AML purposes by the AMLCU in the Department of Justice, whose administrative sanctions regime has been in force since 30 June 2026.
What it is
TCSPs are the businesses that build and maintain corporate and trust structures for clients: forming companies, providing registered office or business addresses, acting as (or arranging for others to act as) directors, company secretaries, trustees or nominee shareholders, and providing similar services. Because those services can be used to obscure who really owns and controls an entity, TCSPs sit squarely inside the AML regime — they are designated persons under the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010.
In Ireland, the AML supervisor for TCSPs is the Anti-Money Laundering Compliance Unit (AMLCU) in the Department of Justice — the same unit that supervises high-value goods dealers and unaffiliated accountants and tax advisers.
Why it matters for Irish firms
Enforcement in this sector has acquired teeth ahead of the EU changes. An administrative financial sanctions regime for the AMLCU has been in force since 30 June 2026 (S.I. No. 307 of 2026), meaning the AMLCU can pursue administrative sanctions against the firms it supervises rather than relying solely on criminal routes. For TCSPs, the compliance bar rose before the AMLR even arrives, and Ireland's AML/CFT Action Plan for 2026–2027 signals sustained supervisory attention.
TCSPs also live closest to the beneficial-ownership machinery: obtaining RBO extracts before new business relationships, comparing register entries against what the client says, and reporting discrepancies. A TCSP's files are, in effect, a map of who controls its clients' structures — which is exactly what an inspection examines.
What changes under the AMLR
From 10 July 2027, Regulation (EU) 2024/1624 (AMLR) replaces the substantive CJA 2010-era rulebook. TCSPs become obliged entities under a directly applicable EU regulation, with harmonised beneficial-ownership rules at the 25% threshold, CDD on occasional transactions from €10,000, prescribed compliance manager and compliance officer roles, and retain-five-years-then-delete record-keeping. Policies and risk assessments written for the old regime will be out of date on the application date.
How CompliDesk helps
CompliDesk Ireland gives TCSPs an AMLR-ready policy pack, RBO workflow and client due diligence in one platform — see pricing or book a demo.
General information, not legal advice. This definition provides general information about EU and Irish anti-money-laundering requirements. Regulatory detail is still evolving through 2026–27 — verify against primary sources (EUR-Lex, AMLA, and your sector’s Irish supervisor) and seek qualified advice before acting.