GIFCS Standard on the Regulation of Trust and Corporate Service Providers (Version 1.2, January 2026)

Summary

This is the GIFCS (Group of International Finance Centre Supervisors) Standard on the Regulation of Trust and Corporate Service Providers, Version 1.2 (January 2026), made available by the GFSC as guidance. It is an international benchmark document setting out minimum principles that a Regulator and a jurisdiction's legislative framework should meet when licensing and supervising Trust and Corporate Service Providers (TCSPs). It does not itself impose direct statutory obligations on Guernsey-regulated firms, but describes the standards Regulators (including GFSC) are expected to apply, and by extension the practices TCSPs should be able to demonstrate.

• Licensing: Regulators should license TCSPs and assess, at licensing and on an ongoing basis, whether the TCSP, its Controllers and Key Persons are fit and proper, with power to withdraw licences for material breach.
• Physical presence and resourcing: TCSPs should demonstrate a genuine physical presence and be adequately resourced, structured and organised to manage the Legal Vehicles and assets they administer.
• Corporate governance: TCSPs should have a robust governance framework, with a Board of at least two sufficiently independent individuals, clear delegation records, succession planning and business continuity plans.
• Control over Legal Vehicles and financial crime: TCSPs should maintain policies, procedures and controls to identify ultimate beneficial owners, comply with AML/CFT and international sanctions requirements, and report suspected sanctions matches to competent authorities.
• Conduct, prudential and administration standards: The Standard sets minimum requirements on conduct towards Clients, prudential soundness, and administrative matters such as Client Money handling.
• Record retention: Where a TCSP is wound up or dissolved, liquidators or custodians of its books and records must retain those records for a minimum of five years.
• Regulatory cooperation: Regulators should have legal authority to share information domestically and internationally without needing an MOU, and should be able to participate in supervisory colleges and permit foreign on-site inspections.

Because this is an international model standard rather than Guernsey-specific legislation, readers should check whether and how GFSC has incorporated these principles into binding Guernsey rules or codes for TCSPs; the document itself functions as a benchmark and guidance reference.

Key obligations

• Regulators should require TCSPs to maintain a physical presence and adequate resourcing appropriate to the Legal Vehicles and assets administered
• TCSPs' Boards should comprise a minimum of two sufficiently independent individuals to direct the business
• Boards should approve and regularly review a compliance policy and maintain a resourced compliance function
• TCSPs should maintain policies, procedures and controls enabling accurate identification of ultimate beneficial owners of Legal Vehicles
• TCSPs should ensure staff have appropriate knowledge of relevant sanctions regimes and inform competent authorities forthwith of suspected sanctions matches
• Liquidators or custodians of a wound-up TCSP's books and records must retain those records for a minimum of five years
• Regulators should maintain mechanisms to share information proactively with domestic and foreign counterparts on request and at their own initiative

Applies to

Trust and Corporate Service Providers (TCSPs), Regulators/supervisory authorities, jurisdictions establishing TCSP regulatory frameworks

Deadlines

• five years: Minimum period liquidators or other custodians must retain a wound-up or dissolved TCSP's books and records