The European Fourth Anti-Money Laundering Directive: Amendments to the UK’s Persons with Significant Control Regime

On 26 June, 2017, a number of changes to the requirement for UK incorporated companies and certain other legal entities to maintain a publicly accessible register of persons with significant control (the “PSC Regime”) were introduced by the Information about People with Significant Control (Amendment) Regulations 2017 (the “PSC Amendment Regulations”).

These changes have been made as a result of the requirements of the European Fourth Anti-Money Laundering Directive, with which the UK was required to comply by the end of June 2017.

Of the changes introduced by the PSC Amendment Regulations, the following are likely to have the greatest impact on companies and other legal entities subject to the PSC Regime:

• Issuers with voting shares admitted to trading on a prescribed market now fall within the scope of the PSC Regime and have been given until July 24, 2017 to comply with their obligations under the PSC Regime.
• The introduction of a 14-day period to notify Companies House of any changes to a PSC Register. The PSC Regime previously required only an annual update to PSC Registers as part of a company’s or legal entity’s confirmation statement.

This memorandum summarizes the key aspects of the PSC Amendment Regulations and their practical implications for companies and other legal entities subject to the PSC Regime.