New measures to help prevent money laundering and terrorist financing are on their way.
On 26 June 2017 changes will be made to UK anti-money laundering measures which are designed to help prevent money laundering and terrorist financing. These measures will increase the transparency of who owns and controls companies in the UK.
How does this affect ACCA members and their clients/companies? Most companies will only have submitted their first confirmation statement. This normally involves firms incorporated prior to 30 June 2016 inputting details of PSCs and a full statement of capital with the confirmation statement. This was initially needed as Companies House would not have this information. Each year the company then needs to confirm those details.
Where changes had occurred in the year, affecting areas like the statement of capital, shareholder information and SIC codes, the current rules are that these could be updated on the confirmation statement.
The revised legislation will make changes to the current requirements relating to significant control (PSC) information and reporting. ACCA members who are involved in filing the statements need to be aware of the new rules to avoid late/inaccurate reporting.
The new rules mean that from 26 June changes to the PSC information cannot be updated on the confirmation statement (CS01). So effectively changes since the previous statement cannot be reported annually.
Instead forms PSC01 to PSC09 will need to be submitted detailing the changes. The company has 14 days to update their register and another 14 days to send the information to Companies House. This is a major alteration to the requirements so it is essential that clients understand their reporting responsibilities and inform their accountant of any changes on a timely basis.
To confuse matters slightly, the following should be noted:
There is no alteration to the existing rule that changes to a company’s officers, registered office address or the address where records are kept must be made separately.
Form PSC01 (alteration form) is already in use but used to notify Companies House of an individual with significant control when the company has elected to keep PSC register information on the public register. This election is voluntary and if made would normally mean that more personal information will be visible to searchers than would otherwise be the case.