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Important changes to UK anti-money laundering rules
Important changes to UK anti-money laundering rules are due to be phased in on 26 June 2017, and we are urging all of our clients to keep up to speed with the new requirements these changes will bring.
What is a PSC register?
One of the changes to UK company law initiated by the Small Business, Enterprise and Employment Act 2015 (the “Act”) is the requirement for details of individuals who own or control more than 25% of a UK company’s shares or voting rights, or who otherwise exercise significant influence or control over a UK company or its management, to be included on a private and public register called the PSC (or “persons with significant control”) Register.
From 26 June 2017, companies will be unable to update their ‘PSC register’ through the Confirmation Statement. Note that even if the review date for the Confirmation Statement is before 26 June, if the date of filing falls after this date, we will not be able to update the PSCs through the CS01 form. The Confirmation Statement will now just be used to update the following:
Please note that although we can no longer update the PSC register through the confirmation statement, we can however use this form to notify Companies House that the Company is exempt from disclosing information on their PSCs (where applicable of course).
From 26 June, we must use forms PSC01 & PSC09 to update Companies House when they need to be informed of any changes to the PSCs. These forms are much the same as what we would previously submit on Confirmation Statements, however when a change occurs, companies will now have 14 days to update their PSC register and a further 14 days to notify Companies House of the change.
This means that instead of updating this register annually and only considering this once a year, the Directors of Companies will have to be a lot more active in reviewing and updating their list of PSCs and therefore Companies House should be able to display a more up to date view of companies.
With regards to the protection rule Companies House have also stated that that currently only public authorities have access to data not disclosed on the public register (such as the day of a PSCs date of birth). The new anti-money laundering legislation means that credit & financial institutions will be able to access this data where deemed necessary by Companies House as they carry out consumer due diligence.
If you would like to find out more about the upcoming changes to anti-money laundering rules please do not hesitate to contact us.
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