Updates to the EU Money Laundering Directive and the Financial Conduct Authority’s (FCA) Financial Crime Guidance Manual have introduced changes that directly impact how we handle withdrawals and process requests from our clients, especially those involving trust corporations.

Understanding the Changes

For our clients, this means that banking platforms have taken in house, the Money Laundering checks and therefore require additional information from trust corporations to ensure compliance. This will affect all clients who are within a Trust Corporation.

A Dedicated Team for Seamless Transitions

Our team is ready and equipped to guide you through the required processes and assist in gathering any necessary documentation. This team will continue to work side-by-side with you to collect all the necessary data without heavy lifting on your part to ensure that the information we hold remains accurate.

What information do we need?

Due to the nature of the information required, in most cases it will be another contact within the trust corporation that we need to speak with. We simply need direction from you as to who is best placed to support us in gathering this information.

Here’s what we need:

  • Ownership and Control Structure: Please provide a chart or a written statement from your company secretary/ authorised signatory or your Compliance Officer, that details your ownership and control percentages.

  • Governance and Control Policies: A confirmation of your control frameworks and policies from a senior management official or your Compliance Officer.

  • Information Required for Key Individuals and Entities: Directors: Full names, residential addresses, and dates of birth for all directors; please include IDs as listed on Companies House.

  • Shareholders: Details of any individual or entity that directly or indirectly owns more than 10% of shares.

  • Ultimate Beneficial Owners (UBO): Information on any individual who ultimately owns more than 10% of shares.

  • Persons with Significant Control (PSC): Information on anyone who has more than 10% of voting rights or significant control over the entity.

  • Senior Operations Management: Names and positions of senior managers responsible for daily operations.

  • Additional Requirements if No Single Entity Controls 25%: If no individual or entity owns or controls more than 25% of the company, please provide details of the Senior Managing Official who leads the executive team. A declaration from a senior controller confirming that no individual meets the 25% threshold is also needed.

Our Commitment

We’re here to guide you through these changes, every step of the way. If you have concerns about what details are required or how they should be provided, your Frenkel Topping advisor is just a conversation away, ready to offer clear, simple guidance and unwavering support.