In a Members' Update published on 26 August last, the IAPF has confirmed that the Department of Justice, Equality and Law Reform has indicated that the new rules in the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010 (the Act) relating to trusts and company services providers (TCSPs) will only apply to corporate or individual trustees whose business it is to provide trustee services on a commercial basis. While detailed guidance is awaited, this would appear to mean that individuals who act as trustees or as directors of a corporate trustee in an unpaid capacity, and indeed a corporate trustee used solely for the purposes of being trustee of a staff pension scheme, will not be regarded as TSCPs for the purposes of the Act. The full extent of this "exemption" will be explained in further guidance in the form of a detailed FAQ due to be published by the Department.