New Anti-Money Laundering Directive brings New Filing Obligations in relation to ‘Persons with Significant Control’

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As you know from April 2016 Limited Companies in England & Wales were required to keep an up to date register of Persons with Significant Control (PSC). Also from 30th June last year it also became necessary to update Companies House with this information using the Confirmation Statement (form CS01), previously known as the Annual Return.

On 26th June this year we had a new Anti-Money Laundering Directive (4AMLD) brought in to lower the occurrence of money laundering and terrorist financing in the UK. Immediately this brings a change to ensure that the PSC register is kept accurate and up to date. From this date any changes to the PSC register need to be updated at Companies House within 28 days of the change taking place.

So if a company has a change in director/shareholder or structure, and this results in a change in the PSC details held i.e. a new PSC is created or an existing one removed, there is a change in the percentage/nature of control or influence of a PSC, or even just a change in personal details of an existing PSC, then the register must be updated within 14 days of the change, with a further 14 days to update Companies House using form PSC01 or PSC09 as appropriate. It is no longer appropriate to update Companies House once per year using the form CS01.

If you require any help or further guidance in this area then please do let us know.

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