To report or not to report: that is the question
06 Jul 2017
The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (the Regulations) came into force on 26 June 2017 (see here). There is limited guidance published but the Regulations apply to, amongst others ‘Trust or company service providers’. There is some confusion as to whether these Regulations apply to non-resident trustees and CSPs and any associated trusts and a great deal of commentary published alludes to the fact that certain non-resident trusts may still be caught. The position is not yet clear but the answer to this seems to lie in whether the trust company is carrying on business in the UK (ie are they relevant persons).