5th EU Anti-Money Laundering Directive – registration of UK trusts

The EU 5^th Anti-Money Laundering Directive (AMLD 5) requires member countries to put regulations in place to extend the requirement of trustees to register trusts on a centrally held trust register.  This directive is enacted in the EU Beneficial Ownership Trust Regulations 2021 (Ireland) and the Money Laundering and Terrorist Financing (Amendment) (EU Exit) Regulations 2020 (SI 2020/991) (UK).

We have identified an issue in the Irish Revenue’s guidance around whether UK trusts sold with an Irish offshore bond should register on the Irish trust register as well as the UK one.  This potential dual registration would impact the Wrap International Portfolio Bond, which is an offshore bond manufactured in Ireland and available via abrdn’s wrap platform. 

We’re therefore formally raising this with the Irish Revenue and are leading discussions with members of the Association of International Life Offices (AILO) in order to find a robust solution which does not impose unnecessary registration requirements.   

We’ll keep you informed of our progress.  However, if you need any assistance please discuss with your usual abrdn contact.