money laundering registration requirements –
commonsense prevails
The Money Laundering Regulations (the Regulations) 2007
came into effect on the 15 December 2007. Under the new
Regulations, HMRC became the supervisory authority for Money
Service Businesses, High Value Dealers, Trust or Company Service
Providers and Accountancy Service Providers.
Originally, it appeared that the Regulations applied to all
Trust or Company Service Providers, including pension scheme
trustees who provided services on a remunerated basis (and arguably
even trustees who received paid expenses). The practical effect of
this would have been that such individuals would have to put
anti-money laundering controls in place and register with HM
Revenue & Customs if they were not already supervised by the
FSA or a designated professional body. Additionally, there was also
a fee to pay for this registration and a fit and proper test to be
undertaken.
Thankfully, common sense has prevailed and individuals or
companies who only provide trustee services to occupational pension
schemes are now stated to be outside of the definition of Trust and
Company Service Provider.
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