Do you deal with overseas Trusts and Company Service Providers (TCSPs)?

According to the Treasury and Home Office “National Risk Assessment of Money Laundering and Terrorist Financing 2020”:

“Evidence has demonstrated the laundering of millions of pounds through UK legal entities established by TCSPs. The risk of TCSPs being used to facilitate money laundering is therefore rated high.”

This is because overseas TCSPs are not subject to UK money laundering regulations.

Unless the TCSP is itself regulated by HMRC or the FCA, we are unable to rely on transparency for anti-money laundering purposes and we must unravel the ownership structure to identify the Ultimate Beneficial Owner (UBO). This means that the applicant must submit official entries from the regulators of the overseas jurisdiction confirming the directors, shareholders, nominees, etc of every entity in the chain together with ID documents of all controlling individuals. In our experience, this can be a very long chain with links in several jurisdictions.

Until we start the process, we have no way of telling how many entities or individuals will be involved and we will ask for a payment on account to cover abortive KYC investigations. This currently stands at £1,500 plus VAT.