On 15 September 2016, HM Treasury launched a consultation into the transposition of the Fourth Money Laundering Directive ("MLD4") into UK law. MLD4 requires Member States to create a central register that holds information on the beneficial ownership of corporate and other legal entities. The transposition deadline for MLD4 is currently 26 June 2017, but the Commission has proposed expediting this to 1 January 2017.
There are questions remaining over the sufficiency of the present arrangements in the UK. Under the new Part 21A of the Companies Act 2006, companies, limited liability partnerships and Societas Europaeae are now obliged to file a Persons of Significant Control Register at Companies House on an annual basis.
However, MLD4 broadens the requirements. Under MLD4, the information held at the central register must be kept 'current,' i.e. it must be updated when there is a change in beneficial ownership, rather than on an annual basis, as is the case with the PSC Register.
The consultation is open to comments until 10 November 2016. The consultation paper can be accessed here:
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