Money laundering and pensions
Money laundering and pensions

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

  • Money laundering and pensions
  • Anti-money laundering regime
  • How does MLR 2017 apply in respect of pension schemes?
  • Pensions impact of the Fifth Money Laundering Directive (MLD5)
  • Meaning of ‘TCSP’, ‘relevant trust’ and ‘taxable relevant trust’
  • TCSP
  • Relevant trust
  • Taxable relevant trust
  • Meaning of ‘beneficial owner’, ‘settlor’ and ‘potential beneficiary’
  • Record-keeping requirements
  • More...

IP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit transition/implementation period entered into following the UK’s withdrawal from the EU. At this point in time (referred to in UK law as ‘IP completion day’), key transitional arrangements come to an end and significant changes begin to take effect across the UK’s legal regime. This document contains guidance on subjects impacted by these changes. Before continuing your research, see Practice Note: Brexit and IP completion day—the implications for pensions.

Anti-money laundering regime

The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, SI 2017/692 (MLR 2017) form part of the UK's overall anti-money laundering and counter-terrorist financing regime. They came into force on 26 June 2017 to give effect to the Fourth Money Laundering Directive (MLD4), in line with Article 67 of that Directive. The MLR 2017 replace the Money Laundering Regulations 2007, SI 2007/2157 (the old Money Laundering Regulations 2007).

The MLR 2017 set administrative requirements which run parallel to the criminal element of the anti-money laundering and counter-terrorist financing regime contained in the Proceeds of Crime Act 2002 and the Terrorism Act 2000. There is some overlap with this legislation.

The MLR 2017 were adopted following two consultations by HM Treasury:

  1. a first consultation on the transposition of MLD4 launched in September 2016, and

  2. a further

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