LMA responds to Treasury consultation on MLD4

The LMA has responded to HM Treasury’s consultation on the transposition of the Fourth Money Laundering Directive (MLD4) into national law.

The LMA has said that there are certain instances where the obligation to disclose the beneficial ownership of legal entities needs to be clarified to avoid disruption to legitimate corporate activities which use beneficial ownership structures.

They have commented on aspects of the existing People with Significant Control (“PSC”) regime and the disclosure of the beneficial ownership of trusts. Amongst other things, they are concerned about potential ways in which banks could be caught under the PSC rules, for example where they take security over shares in a company. They also argue against applying unduly onerous reporting requirements to syndicated loans, such as an obligation to update the regulator every time a loan is traded.

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