21st September 2021
Prudential: Trust Registration Service (TRS)
Learn about the requirements of the TRS which became operational on 13 July 2017.
- The TRS originally reflected government obligations under 4MLD. We now have 5MLD to consider
- 5MLD is effective from 6 October 2020 with regard to TRS aspects
- 5MLD extends the scope of the TRS and widens the definition of trusts required to register
- Registration deadlines apply
Money Laundering Directives
The UK government obligations under the Fourth Money Laundering Directive (4MLD) came into effect in June 2017 (see here). Amendments to Regulations implementing 5MLD came into force on 10 January 2020. However, so as to allow for further consultation, this did not include changes required to the TRS. A government consultation was launched on 24 January 2020, running to 21 February 2020 to consider the knock on changes necessary to the TRS. On 15 July 2020, the government published the main responses received and the next steps. TRS regulations under 5MLD came into force on 6 October 2020
This article initially reflects 4MLD obligations before considering the impact of 5MLD. Draft HMRC Guidance dated 22 November 2017 is also considered. There appears to be no published final guidance. This internal HMRC manual was published in May 2021 and covers off the TRS.

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