The UK’s Department for Business, Energy & Industrial Strategy has published a “Discussion paper on the transposition of Article 30 [of the 4th Money laundering Directive]: beneficial ownership of corporate and other legal entities“.

Article 30 of the 4th Money Laundering Directive sets out the Member State’s obligations with respect to the collection and availability of information on the beneficial ownership of corporate and other legal entities incorporated in their territory. Article 30 must be transposed into UK law, and that law must be in force, by June 2017. To achieve this, the UK will need to amend its Companies Act provisions on the People with Significant Control Register to:

  1. broaden the scope of the entities that are required to obtain and hold information – the extended list will cover, for example, unregistered companies, Open Ended Investment Companies, Investment Companies with Variable Capital, building societies, friendly societies and credit unions;
  2. include more information about the beneficial owners of, and the nature and extent of the beneficial interest(s) they hold in, every relevant type of corporate entity;
  3. change the frequency with which information must be registered, to ensure the adequacy, accuracy and currency of the information in the register;
  4. (perhaps) make more information available about registered beneficial owners.

The 5th Money Laundering Directive is expected to change the 4th Money Laundering Directive’s beneficial ownership information requirements, when it’s agreed and brought into force. The transposition deadline for the 5th Directive is expected to be June 2017, as well. So another Discussion Paper on Consultation Paper, and an additional set of PSC Register changes, therefore seem inevitable before too long. This “Discussion paper” includes 13 “Consultation questions“. The deadline for responses is 16 December 2016.