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Part I: Belize Law, Courts and Regulators · Chapter 3

The Financial Services Commission and the Licensing of Trust and Company Service Providers

Lighthouse on Belize: Trusts, LLCs, and Foundations · ¶ 301 to ¶ 390 · 10 sections

301

Overview

The regulator and the regulated. Every Belize international trust, LLC and foundation reaches the public record through a licensed intermediary. A Belize trustee or trust agent registers the international trust, a registered agent forms the LLC and the company, and a registered agent acts for the foundation. Each of those intermediaries holds a licence from the Financial Services Commission, and the Commission's Director General keeps the registers on which the protection of an international trust and the existence of an LLC or foundation depend (see supra¶ 140.04–140.05). The quality of a Belize structure therefore depends in practice on two matters that the client does not see: whether the intermediary is properly licensed and supervised, and whether it keeps the records and makes the filings the law requires. This chapter examines both.

The statute. The Financial Services Commission Act, No. 8 of 2023 ("FSC Act"), assented to and gazetted on April 15, 2023, repealed the International Financial Services Commission Act, Cap. 272, and established the Financial Services Commission as the regulator of financial services conducted in or from within Belize, other than banking, international banking and credit-union business. FSC Act ss. 2, 3, 82(1). It has been amended three times: by Act No. 47 of 2023, by the Financial Services Commission (Amendment) Act, 2024, No. 39 of 2024, which reconstituted the chairmanship of the Appeal Panel and made unpaid administrative penalties enforceable as judgments, and by the Financial Services Commission (Amendment) Act, 2026, No. 8 of 2026, which provides for special licences for digital-asset businesses. Act No. 39 of 2024, s. 1 (reciting Act No. 47 of 2023), ss. 2–4; Act No. 8 of 2026, ss. 1–3. The Commission has made three sets of regulations under the Act that matter most to trust and company work: the Financial Services Commission (Licensing) Regulations, 2023, S.I. 120 of 2023 ("Licensing Regulations"); the Financial Services Commission (Financial Services Practitioners Code of Conduct and Best Practices) Regulations, 2023, S.I. 128 of 2023 ("Code of Conduct"); and the Financial Services Commission (Nominee Shareholders and Directors) Regulations, 2025, S.I. 158 of 2025 ("Nominee Regulations"). Capital requirements remain those of the Capital Requirement Regulations of 2020, continued under the savings provision of the 2023 Act. FSC Act s. 82(3).

Three regimes in one. A Belize trust or company service provider is regulated under three bodies of law at once. The FSC Act and its regulations govern licensing, conduct and prudential matters. The trust, LLC, foundation and company statutes impose their own registration and record-keeping duties on the trustee, trust agent or registered agent, and make the Director General the Registrar for several of them. Trusts Act, Cap. 202, ss. 65A–65G (rev. ed. 2020). The Money Laundering and Terrorism (Prevention) Act, Cap. 104 ("MLTPA"), designates the Commission as the supervisory authority for trust and company service providers, with its own sanctions. MLTPA s. 2 & sched. III, item 25. A licensee that complies with one regime and neglects another can lose its licence.

Plan of the chapter. Paragraph 310 traces the move from the International Financial Services Commission to the present Commission. Paragraph 320 describes the Commission's constitution, functions and powers. Paragraphs 330 through 350 examine the licensing regime: who must hold a licence, how one is obtained, and the terms, duration and renewal of a licence. Paragraph 360 sets out the continuing obligations of licensees under the Act and the Code of Conduct. Paragraph 370 covers supervision, enforcement and appeals, and paragraph 380 the Commission's power to share information with other authorities. Paragraph 390 draws the practical lessons for a planner who must choose and then supervise a Belize trustee or registered agent.

Why the planner should care. The protective provisions of the Trusts Act, the LLC Act and the Foundations Act operate on a structure that has been validly created and registered. A trust whose agent failed to register it within ninety days, or whose registration was cancelled because the agent resigned and no successor was appointed, may not be an international trust at all when a creditor arrives (see infra chs. 6 and 11). An LLC whose registered agent lost its licence may be struck off. A trustee whose licence is suspended may be unable to act at the moment a duress clause or a protector's direction requires it. Regulatory status is therefore part of the asset-protection analysis, and the planner who documents a structure's protective features should document the regulatory standing of the intermediaries with the same care.

Sources. The chapter relies on the official texts of the FSC Act and its amending Acts, the regulations made under it, the Trusts Act and the MLTPA, as published by the Commission and the Attorney General's Ministry. Where it relies on the Commission's published guidance, frequently asked questions or public notices for a point the statute does not settle, it says so. Fee amounts in particular change frequently and are stated as the Commission published them in 2026.

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The sections that follow

  1. 310 From the International Financial Services Commission to the Financial Services Commission
  2. 320 The Commission: Constitution, Functions and Powers
  3. 330 Who Needs a Licence
  4. 340 Obtaining a Licence: Eligibility, Fitness and Propriety, Capital and Insurance
  5. 350 Terms of the Licence, Duration, Renewal and Revocation for Default
  6. 360 The Continuing Obligations of Licensees
  7. 370 Supervision, Enforcement and Appeals
  8. 380 Information Sharing and International Cooperation
  9. 390 Choosing and Supervising a Belize Trustee or Registered Agent

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