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Important changes to money laundering regulations (MLR) registration requirements for Trust or Company Service Providers (TCSPs)

28 March 2008
Mayer, Brown, Rowe & Maw LLP
28 March 2008 - HMRC have put back the deadline to apply to register as a TCSP until 31 May 2008 (formerly 31 March 2008).

As a result of significant lobbying from the pensions industry,  HMRC have announced that the MLR 9 Registration Guidance for TCSPs will be updated in April to reflect the concerns.

The postponement of the 31 March deadline is said to be designed to enable potentially affected parties to consider the updated guidance and their subsequent need to register as a TCSP or not.

Commenting on the changes, Jonathan Moody, a partner at Mayer Brown in London, said: "HMRC meant to be helpful by offering guidance, but the published guidance fudged the issue for trustees in a grey area who aren't clearly in or out of the frame. And unfortunately that includes trustees who are paid anything more than a token amount to make up for the extra work they are taking on."

He added: "Most paid trustees know they aren't in business, but still, criminal penalties are a concern and they feel pressured into registering just to be on the safe side. Often it's not the cost that worries them but the ongoing obligations they might then have to comply with as some kind of watchdog.  We have voiced our concerns for some time over this. But we should be grateful that HMRC have finally listened, even though it's at the eleventh hour."

For further information:
Jonathan Moody
Partner, London
+44 (0)20 7334 2047

Charlotte Ward
PR Manager, London
+44 (0)20 7782 8547

Related Information

  • Related People
    Jonathan Moody
    Legal Professional / Consultant
    T +44 20 3130 3042

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