At fscom, it’s our job to keep you in the know, so we just wanted to send you a reminder of your anti-money laundering responsibilities under the Fourth Money Laundering Directive (4MLD). Here are the two key points to be aware of:
- By 6 April 2016 Companies will have to maintain their own Persons with Significant Control (PSC) register.
- From 26 June 2016 Companies will have to file their PSC information with Companies House.
While the requirement to file the information and maintain a register is a burden on firms, there is innate benefit for firms carrying out their own Customer Due Diligence to have a centralised and updated source of UBO information they can readily access.
The Department of Business, Innovation and Skills is taking the lead on this and they have issued guidance for companies to follow. By the 6 April deadline your company should have a register that records the details of any individual who holds more than 25% of shares or voting rights in the company.
Additionally, you are expected to determine and record the details of an individual who can appoint or remove the majority of the board, or more broadly, anyone who ‘exercises significant influence or control’ over the company. A comprehensive list of the pedigree information to be included on the register is available here.
Listed companies, including AIM firms, are already covered under the DTR5 disclosure requirements, and are therefore exempt from the requirement to maintain a PSC register.
Contact us for more information on 4MLD and what it means for your business.
