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HMRC internal manual

Money Laundering Regulations: Compliance

Trust or Company Service Providers (TCSPS): Compliance checks at a visit to a professional trustee

It is essential that a professional trustee can demonstrate that it has an effective risk assessment in place for each of the trusts for whom it acts that addresses the risk of money laundering posed by persons connected to the trust. Matters to be taken into account should be:

* identity of the Settlor
* identity of the beneficiaries
* purpose of the Trust
* sources of money or other assets contributed to the trust
* location of Trust (offshore?)
* linkage between other trusts and companies and ease of following audit trails
* any offshore transactions
* has the trust made any loans?
* history of any previous trustees and reasons for leaving.