HM Revenue & Customs (HMRC) has updated its money laundering guidance, MLR9, providing guidance on the requirements to register under the Money Laundering Regulations 2007 (the Regulations).
The Regulations require “Trust or Company Service Providers (TCSPs)” to register with HMRC. There had previously been some uncertainty as to whether paid pension trustees would count as TCSPs and so liable to register. For background see EPB bulletin 25 February 2008 and EPB bulletin 25 June 2008.
The updated guidance now makes it clear that sole practitioners and firms will not be TCSPs if they provide trustee services limited to occupational pension schemes.