Under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations (“MLR”) 2017 (regs 42 - 45) there is a requirement to maintain a beneficial register of trusts. Under the Trust Registration Service (“TRS”), Trustees are required to register a Trust if it has a taxation consequence.
Is compliance with the TRS also compliance with the MLR 2017?
I suspect this may be obvious for many. What I am struggling with is whether, irrespective of the TRS requirements, we should be maintaining a separate independent register of beneficial ownership of Trusts that we deal with.
Brewer Harding & Rowe