Trustees and the new anti-money laundering regime
Changes made to the UK anti-money laundering regime from 15 December 2007 require trustees and directors of a corporate trustee who are providing their services “by way of business” to comply with certain anti-money laundering requirements. Trustees who fall outside this definition are excluded from the regime. There are tough penalties for failure to comply with the anti-money laundering regime. For instance, a civil penalty could be imposed on a trustee (or director) who fails to put in place adequate anti-money laundering systems or who fails to report a suspicious transaction.