Beneficial ownership registers—private clients and trusts

The following Private Client practice note provides comprehensive and up to date legal information covering:

  • Beneficial ownership registers—private clients and trusts
  • Global developments towards beneficial ownership transparency
  • Sanctions
  • CDOTs
  • The PSC Register
  • Registration of overseas entities holding UK property
  • 4MLD and 5MLD beneficial ownership registers
  • What is the meaning of beneficial ownership under 4MLD and 5MLD?
  • 4MLD and the PSC regime
  • How does 4MLD and 5MLD apply to the beneficial ownership of trusts?
  • More...

Beneficial ownership registers—private clients and trusts

CORONAVIRUS (COVID-19): Certain aspects of the PSC regime are affected by temporary measures introduced to mitigate the consequences of the coronavirus (COVID-19) pandemic, for example the deadline to notify the registrar of changes to the PSC register is increased from 14 to 42 days. For further guidance, see Practice Note: Coronavirus (COVID–19)—impact on company filing and administrative procedures.

This Practice Note provides a summary of the steps taken by the UK, the EU and the G20 towards transparency and highlights issues that may be of particular interest to Private Client practitioners and trustees.

For guidance on the due diligence requirements imposed on Private Client practitioners or their law firms, see Practice Compliance content, including: AML and counter-terrorist financing—Client due diligence—law firms—overview.

Global developments towards beneficial ownership transparency

In 2014, the G20 agreed high-level principles on beneficial ownership transparency.

In March 2015, the UK government introduced legislation which requires a UK entity to keep a register of people who have significant control (PSC) over the entity (the PSC Register) from April 2016. A public register of PSCs became operational on 30 June 2016.

In May 2015, the EU adopted the Fourth Money Laundering Directive (4MLD), which imposes a requirement to store beneficial ownership information in a central register. 4MLD was amended and extended by 5MLD, which was published in the EU official journal on 19 June 2018 and came into

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