From 1 April 2023, the reporting requirements for the Trust Registration Service (“TRS”) were expanded. As a result, HMRC updated the TRS manual.
An online form must now be used to report “material discrepancies”. This does not include small spelling errors or slight differences in the trust name, so long as the trust is identifiable from the trust name on the TRS.
A relevant person is now required to conduct ongoing due diligence throughout a business relationship with a registerable trust, and prior to engaging in the relationship. Ongoing monitoring must also be carried out in line with the relevant person’s money laundering obligations.