Trust and Company Service Providers (TCSPs)

Professionals or firms that provide services associated with the formation, administration, and management of companies, trusts, or similar structures on behalf of clients. Their offerings can include company formation, registered office provision, directorship or nominee services, trust administration, accounting, tax compliance, and other administrative or fiduciary duties, often operating across multiple jurisdictions.

[
Code
AT0035
]
[
Name
Trust and Company Service Providers (TCSPs)
]
[
Version
1.0
]
[
Category
Professional Services & Advisors
]
[
Created
2025-03-12
]
[
Modified
2025-04-02
]

Related Techniques

Trust and company service providers facilitate the creation and ongoing maintenance of complex corporate or trust structures by:

  • Forming offshore entities, holding companies, or trusts that disguise the true actors behind arbitration claims.
  • Managing cross-border transfers labeled as settlement payments, reducing transparency for financial institutions.

These layered arrangements impede traceability and make it difficult for banks or regulators to link funds back to criminal sources.

TCSPs assist in forming and administering opaque corporate or trust structures that criminals use for asset management deposits.

  • They manage documentation and entity creation, preventing clear identification of the ultimate owners.
  • Financial institutions face heightened difficulty conducting meaningful KYC or tracing funds when TCSPs layer these structures across multiple jurisdictions.

TCSPs enable criminals' use of bearer instruments by:

  • Incorporating entities that issue bearer shares, circumventing formal ownership disclosure requirements.
  • Structuring complex corporate arrangements that hinder financial institutions' attempts to identify the ultimate beneficial owners.

Criminals contract TCSPs to establish and administer entities or trusts with exaggerated secrecy features. By frequently changing the listed owners or beneficiaries, TCSP-managed structures obscure who ultimately controls the funds or assets, complicating beneficial ownership checks for financial institutions.

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Criminals leverage these providers to:

  • Rapidly create or maintain multiple shell or front companies across various jurisdictions.
  • Provide management and administrative services that enable repeated VAT refund claims despite little to no genuine business activity.
  • Obscure beneficial ownership and the repetitive nature of phantom trades, complicating financial institutions’ due diligence.

They help establish and administer corporate entities—often unwittingly—for criminals involved in environmental crimes by:

  • Registering shell or front companies used to mix illicit and legitimate revenues.
  • Offering nominee or directorship services that obscure actual control.

Such arrangements hamper financial institutions' ability to confirm beneficial ownership or detect atypical account activity.

TCSPs support opaque corporate structuring by:

  • Forming new entities, appointing nominees, or providing registered office services across jurisdictions with weak disclosure.
  • Maintaining layered corporate arrangements, complicating beneficial ownership checks for financial institutions.

Professionals or firms that create and administer corporate structures or trusts used in deceptive tax filings:

  • Establish complex or layered entities enabling criminals to mask real assets and beneficial owners.
  • Facilitate the filing of incorrect or incomplete tax returns under the guise of legitimate corporate or trust arrangements.
  • Complicate financial institutions’ ability to identify true controllers or verify the source of funds when reviewing account applications and transactions.

Criminals enlist TCSPs to establish multiple entities and trust arrangements by:

  • Incorporating layered structures that obscure ultimate beneficiaries.
  • Citing professional confidentiality to resist deeper scrutiny.

This limits financial institutions' access to accurate ownership information, frustrating ongoing due diligence and KYC procedures.

Trust and company service providers establish and administer specialized fiduciary or mutual trust fund vehicles tied to fictitious foreign investments.

  • They create layered ownership structures or pooled accounts, obscuring the identity of actual contributors.
  • This secrecy hinders financial institutions' efforts to perform effective due diligence on beneficial owners and fund sources.

TCSPs play a role in fictitious trading by:

  • Forming and administering intricate corporate structures and shell entities spanning multiple jurisdictions.
  • Allowing criminals to conceal beneficial ownership behind complex arrangements.

Financial institutions face increased difficulty in tracing the true controllers of these entities and in detecting the fraudulent nature of cross-border transactions.

These providers enable criminals to form and maintain corporate or foundation structures that underpin freeport storage by:

  • Incorporating and administering shell or offshore companies that hold high-value assets.
  • Arranging nominee directors or shareholders to create additional layers of anonymity.
  • Managing payment and document filings for storage fees, further complicating financial institutions’ due diligence efforts.

Forms the company, supplies “shelf” entities or nominee directors, and files annual returns, thereby furnishing the illicit operator with a ready-made legal façade and cross-border corporate structure that obscures true ownership.

TCSPs facilitate the creation and administration of legal structures exploited for relief fraud. They:

  • Form shell or nominee-based entities used to submit fraudulent applications and receive disbursements.
  • Obscure beneficial ownership, complicating KYC and transaction monitoring efforts by financial institutions.

These service providers facilitate the formation and administration of trusts or corporate vehicles used for:

  • Establishing multi-layered structures that shield beneficial owners from scrutiny, enabling criminals to route funds through multiple jurisdictions.
  • Creating and maintaining corporate records, registered offices, and nominee arrangements that obscure links between property holdings and illicit fund sources.
  • Complicating financial institutions’ due diligence efforts by dispersing ownership across various trusts, companies, or offshore entities.
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  • Assist fraudsters in forming or managing offshore and shell entities.
  • Enable the concealment of real principals behind nominee arrangements or multi-layered ownership.
  • Facilitate cross-border structures that hinder investigators from tracing stolen investor funds.

These providers create and manage corporate entities across multiple jurisdictions by:

  • Handling entity formation, registered addresses, and administration services.
  • Offering nominee director or shareholder arrangements that veil beneficial owners.

Criminals exploit such services to layer funds and reduce transparency, impeding financial institution due diligence.

TCSPs form and register offshore gambling entities on behalf of criminal clients, providing nominee directors or shareholders to conceal the true owners.

  • Designing opaque corporate structures makes it difficult for financial institutions to identify ultimate beneficial owners.
  • By managing legal documentation and administrative tasks, TCSPs enable offshore setups with limited transparency or regulatory scrutiny.

TCSPs establish opaque corporate and trust structures that:

  • Enable the layering of funds across offshore jurisdictions.
  • Mask true ownership and financial control using complex legal arrangements.

This hinders financial institutions' ability to perform enhanced due diligence and identify the ultimate beneficiary of transferred funds.

Criminals employ trust and company service providers to:

  • Set up and administer entities or trusts in secrecy-friendly jurisdictions, obscuring beneficial ownership.
  • Provide nominee or proxy services that shield the true owners’ identities.

Such arrangements hinder financial institutions’ AML efforts by fragmenting ownership records across multiple layers.

Trust and company service providers are exploited when criminals:

  • Form and administer shell corporations or trusts that bid at auctions on behalf of hidden beneficiaries.
  • Layer ownership chains, preventing clear identification of the true controlling parties.
  • Allow ongoing transactions and flips through these structures, challenging financial institutions' ability to track illicit capital flows.

TCSPs facilitate real estate-based laundering by:

  • Forming and managing trusts or corporate vehicles that purchase properties on criminals’ behalf.
  • Designating nominee directors or shareholders to obscure the actual individuals controlling the assets.
  • Layering ownership across multiple jurisdictions, complicating law enforcement and bank inquiries into the origin of funds.

This structure significantly impedes financial institutions’ ability to identify ultimate beneficial owners and assess money laundering risks in real estate deals.

Criminals rely on trust and company service providers to:

  • Create and administer shell or corporate structures listed as property owners.
  • Obscure beneficial ownership and funnel illicit proceeds disguised as rental income, complicating financial institutions' investigations into the funds' source.
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Trust and company service providers facilitate the sale of dormant shelf companies by:

  • Maintaining pre-registered corporate entities with aged inception dates, which increases perceived legitimacy.
  • Providing or arranging nominee directors or staff, making beneficial ownership harder to trace.
  • Streamlining the immediate transfer of control, reducing scrutiny for suspicious changes in directorship or ownership.

TCSPs may set up or administer entities and trusts that:

  • Layer ownership across multiple jurisdictions or nominee arrangements.
  • Mask personal or corporate income, frustrating accurate tax assessments.

By designing and maintaining complex structures, TCSPs become channels—wittingly or unwittingly—that obscure the identities of actual revenue beneficiaries, complicating financial institutions’ customer and transaction due diligence.

These service providers, knowingly or unwittingly, enable the rapid creation and dissolution of short-lived shell entities by handling registration, corporate documentation, and nominee services. This assistance helps obscure ownership structures and allows criminals to move illicit funds swiftly.

Financial institutions face heightened challenges in verifying beneficial owners when shell companies are set up and dissolved by TCSPs, as records and due diligence information may be incomplete or unavailable by the time suspicious activity is flagged.

TCSPs facilitate the creation and maintenance of virtual companies by:

  • Incorporating business entities remotely in jurisdictions with minimal disclosure, which limits visibility into ultimate beneficial ownership.
  • Arranging corporate layers, including nominee structures and virtual offices, making it difficult for financial institutions to identify controlling individuals.
  • Enabling quick upgrades or closures of these entities, causing continuous challenges for due diligence and oversight.