Implementation of new TRS rules

When does the SI come into force?
What are the deadlines for registration on the TRS?

The Money Laundering and Terrorist Financing (Amendment) (EU Exit) Regulations 2020 were laid before Parliament on 15 September 2020. Among other things, this statutory instrument (SI) implements the new Trust Registration Service (TRS) rules, as extended by the EU Fifth Money Laundering Directive, which came into force on 10 January 2020.

When does the SI come into force?

As previously reported, the TRS rules were extended to require registration of non-UK (and UK) trusts that acquire an interest in UK land, as well as trusts with a UK trustee that enter into a business relationship with a UK-based adviser (or other relevant person). Many of the provisions of the SI, including those relating to such trusts, came into force 21 days after the day on which the SI was laid before Parliament (ie, 6 October 2020). Thus, trustees of relevant trusts who acquire an interest in UK land or enter into a relevant business relationship on or after this date will be within the extended scope of the rules and must register on the TRS by 10 March 2022.

What are the deadlines for registration on the TRS?

Trustees of non-taxable trusts that fall within the extended registration requirements before 9 February 2022 will be required to register by 10 March 2022. From 9 February 2022 onwards, registration will be required within 30 days of the event that triggers registration.

For further information on this topic please contact Julia Ramsden Gunduz or Robert Payne at Forsters LLP by telephone (+44 20 7863 8333) or email (julia.ramsdengunduz@forsters.co.uk or robert.payne@forsters.co.uk). The Forsters LLP website can be accessed at www.forsters.co.uk.