Paid pension scheme trustees: the new money laundering requirements

The money laundering regime requires certain service providers, including some paid pension scheme trustees, to have in place systems to prevent money laundering as well as to report any suspicious transactions to the Serious Organised Crime Agency. Civil and criminal sanctions may be imposed for compliance failures.

New regulations provide that a "firm or sole practitioner who by way of business" acts as a pension scheme trustee must comply with the new requirements and must register with HM Revenue and Customs (HMRC) by 1 April 2008. It is not clear from the HMRC draft guidance exactly how they decide whether a person is acting by way of business as a pension scheme trustee. Therefore, whether or not a trustee needs to register is going to depend on the facts of each case.

Find out more about the implications for paid pension scheme trustees from Wragge & Co's Pensions team.