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HMRC's online Trust Registration Service (TRS) was designed to implement the EU’s Fourth Anti-Money Laundering Directive Directive (EU) 2015/849 (4MLD) through the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017), SI 2017/692 and the EU’s Fifth Anti-Money Laundering Directive Directive (EU) 2018/843 (5MLD) through the Money Laundering and Terrorist Financing (Amendment) (EU Exit) Regulations 2020 (MLR 2020), SI 2020/991. The Money Laundering and Terrorist Financing (Amendment) Regulations 2019, SI 2019/1511 were also made to transpose 5MLD into UK law, but these dealt with the provisions other than those relating to the registration of trusts. This Practice Note therefore focuses on MLR 2017, SI 2017/692 and MLR 2020, SI 2020/991. For further guidance on the transposition of 5MLD into UK law including the consultations which took place, see Transposing 5MLD into UK law below.
MLR 2020, SI 2020/991 amended and extended MLR 2017, SI 2017/692 to significantly increase the types of trusts that must register with the TRS. The TRS has been stated to support the digital direction of HMRC and general tax transparency, and forms part of the UK's overall anti-money laundering and counter-terrorist financing regime. Registration with the TRS is shorthand to describe the way in which trustees of trusts provide beneficial ownership information about the trust
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