the register at Companies House, although it will be accessible by certain public bodies and (unless a PSC
makes a speciï¬c application) credit reference agencies. The PSC’s date of birth will be publicly available on a
company’s own PSC Register, but not on the register at Companies House (unless the company elects to
hold its own PSC Register there). The PSC Regulations also permit PSCs to seek further protection of their
personal information from public disclosure, provided that they can satisfy certain tests relating to there
being a serious risk of harm. This protection regime is based on the existing UK protection regime for
directors.
WHAT’S NEXT?
Companies and LLPs will need to put in place the necessary internal systems to deal with the new regime
and should begin taking reasonable steps to identify PSCs and relevant legal entities and preparing their
PSC Register to be ready for 6 April 2016, when the majority of the PSC Regulations and LLP Regulations
take effect.
Similarly, PSCs who wish to limit the information relating to them that will be publicly available
on the PSC Register should also begin preparing such applications.
Further amendments to the PSC regime are likely in order to bring it fully into line with the requirements of
the Fourth Money Laundering Directive, although such changes are unlikely until next year.
CONTACTS
If you have any questions or would like more information on the issues discussed in this LawFlash, please
contact any of the following Morgan Lewis lawyers:
London
Iain Wright
Ann-Marie Davies
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