The People with Significant Control Regime (PSC), which was included in the Small Business, Enterprise and Employment Act 2015, has been up and running since last year and most will be familiar with the process of the PSC register.
However, on 26th June 2017 -as promised- an enhanced regime was introduced as part of the EU 4th Money Laundering Directive (4MLD). This update has extended the requirement to cover other corporate or legal entities such as Open Ended Investment Companies (OEICS). The definition of an organisation that falls within this regime is that the entity is incorporated within the UK and is capable of having a beneficial owner.
Registers now have to be updated within six months of a change (rather than the previous twelve months) and the exemptions that applied to companies registered on AIM or ISDX have been removed. Companies on regulated markets are excluded from the regime. The need for filing within six months of a change is due to the requirement that registers are adequate, accurate and current. This is in addition to the annual Confirmation Statement.
Nearly all of this information is in the public domain and can be searched worldwide on the internet. Certain matters such as directors’ addresses and dates of birth are restricted but are available to credit checking and financial institutions.
It is the legal responsibility of the company, its directors and the designated LLP members to obtain and confirm PSC information, maintain the entity’s own PSC register and deliver the required PSC information to Companies House on the annual confirmation statement. MSP manages this register for its statutory clients including the annual filing and the filing of changes.
If you would like our assistance in complying to the new regime or more information on the PSC register please get in touch with Philippa Keith on 020 76375216 or at firstname.lastname@example.org