New money laundering registration guidance: HMRC clarifies position for trustees of occupational pension schemes

On 31 July 2008 Her Majesty's Revenue & Customs (HMRC) published updated guidance on the registration requirements for Trust or Company Service Providers (TCSPs) and Accountancy Service Providers (ASPs) under the new Money Laundering Regulations.

Trustees who provide services "by way of business" as a TCSP before 15 December must apply to register with HMRC before 30 September 2008.

However, firms or sole practitioners or directors of corporate trustees who only perform professional trustee services in relation to occupational pension schemes do not need to register.

Wragge & Co's pension experts provide an analysis and action points.