THE FOURTH MONEY LAUNDERING DIRECTIVE
CHANGES TO THE PERSONS WITH SIGNIFICANT CONTROL (PSC) REGIME
The current PSC regime requires information about beneficial owners’ to be disclosed for corporate and other legal entities.
The Fourth Money Laundering Directive (EU) 2015/ 849) (“MLD4”) which takes effect from 26th June 2017 will take this further with two key changes as follows:
- At present, changes to the PSC are notified on the annual confirmation statement via changes made to the PSC register. The effect of this means that the information which is open to the public may be outdated by up to a year. Under the MLD4 the PSC register will have to be updated whenever a change occurs in the company; companies will have 14 days to update their register and file the relevant forms at Companies House within another 14 days. The effect will be that the PSC will remain updated at all time and not only once a year through a confirmation statement.
- The MLD4 also has a wider a scope of application meaning that the PSC regime will need to include more entities.
Companies House is working towards the original timetable, although matters could be delayed due to the parliamentary elections.
Companies would be wise to familiarise themselves with the changes that will be coming and their prescribed time limits. If you need solicitors to help you with your company records and filings we offer a fixed price legal services.
The above is intended as general legal guidance. Please contact us for further information.