The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 ("the Regulations) came into force on 26 June 2017 and impose new registration and reporting duties on trustees, including trustees of pension schemes. Recent guidance from HMRC has clarified the extent of these duties for pension trustees.
In particular, trustees will now need to register their schemes with HMRC’s new Trust Registration Service.
Registration is made online and, for most schemes, must be completed on or before 5 March 2018.
The Regulations implement into UK law the requirements of the EU’s Fourth Money Laundering Directive, and are intended to promote transparency in property ownership and thereby make it more difficult for trusts to be used as vehicles for money laundering. UK occupational pension schemes are typically established under a trust and therefore the Regulations apply to most schemes.