10 January 2020, the deadline for EU Member States implementing the Fifth EU Anti-Money Laundering Directive (AMLD5), has passed. A key feature of AMLD5 is the requirement for all express trusts to be registered in a central national register; a significant expansion of the current trust registration requirement which is limited to taxable trusts. The UK published the Money Laundering and Terrorist Financing (Amendment) Regulations 2019 on 20 December 2019. These regulations implement AMLD5, with the exception of the expanded trust registration requirement.
This briefing note follows on from our December 2019 briefing note and provides an update on what is next for the trust registration requirement.