Anti-money laundering – HMRC u-turn


Since 15 December 2007, “trust or company service providers” (TCSPs) who are providing their services “by way of business” must comply with certain anti-money laundering requirements, including registering with HM Revenue and Customs (HMRC). As we reported back in February, this definition may have included all paid trustees. But HMRC published revised guidance on who needs to register as a TCSP today, 31 July 2008. Whilst the guidance could be clearer, the upshot is that occupational pension scheme trustees are generally excluded from the need to register. This is because one of the exclusions from registration specifically recognises that occupational pension schemes are a low risk area.

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