Thursday, April 1, 2021 The Fourth Money Laundering Directive ((EU) 2015/849) (MLD4) was implemented in the United Kingdom as a result of The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulation 2017 (SI 2017/692). In order to fulfil the requirements of MLD4, HM Revenue & Customs (HMRC) introduced the Trust Registration Service (TRS) to help combat money laundering and terrorist financing in the United Kingdom. Because of further European Directives, the TRS has now been extended with wide-reaching consequences. Read on for a discussion of who is affected and key implications. IN DEPTH What Is the Trust Registration Service? The TRS is an online portal which provides certain trustees and personal representatives with a relatively user-friendly way to satisfy their registration obligations with HMRC. Under MLD4, only specified express trusts with UK tax consequences or “complex estates” needed to be registered. However, the introduction of the Fifth Money Laundering Directive ((EU) 2018/843) (MLD5), which came into effect on 6 October 2020 and aims to reinforce the United Kingdom’s leading money laundering regime, has tremendously broadened this scope. Now, all UK trusts (both express and implied) and “complex estates” must be registered, aside from the small group of identified exceptions.