Hogan Lovells

Key Dates

Minutes of meeting on 23 May 2018.

Policy consultation expected in winter 2018/19.

Consultation on draft legislation expected in spring 2019.

Deadline for transposition into national law expected to be around January 2020.

Deadline for implementation in national law expected to be around March 2020.


In minutes of a meeting about the Trust Registration Service (TRS), HMRC provided an update about the implementation of the Fifth Money Laundering Directive (5MLD).  It comments that 5MLD would extend the TRS to all UK express trusts and non-EU trusts that own UK real estate or had a business relationship with a UK "Obliged Entity" (broadly, an entity subject to money laundering requirements).  5MLD would require HMRC to share trust data with Obliged Entities and anyone with a "legitimate interest" (to be defined in due course).

Date Accessed: 28/05/2022