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Proposed changes to the UK Trust Register - an update

The government has published a Summary of Responses, dated 15 July 2020, to the technical consultation on the implementation of AMLD5 and the Trust Register.

It contains a number of welcome clarifications and refinements to the original proposals, particularly in relation to the ambit of a "business relationship" which, it was feared, would have discouraged trustees of non-EEA trusts from using UK-based advisers, due to the additional costs of complying with TRS and the potential loss of confidentiality as a result of registration.

However, the government has indicated that only non-UK trusts which have at least one UK trustee will be required to register upon entering a business relationship with a “UK obliged entity”. This means that non-UK trusts will not be required to register if their only link to the UK is through a business relationship with a UK based adviser. 

However, there are still some important points of uncertainty.  It will be critical to review the guidance with great care when it is published.

To read more, please click on the link below.

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