Reporting requirements under the UK’s Persons of Significant Control regime have expanded thanks to the EU’s new anti-money laundering directive, which was published last week.
UK limited liability partnerships now have just two weeks to report a change of PSC – instead of “as soon as reasonably practicable” – and must identify their PSCs in an annual confirmation statement sent to Companies House.
Scottish limited partnerships were previously excluded from the requirements, but now must report in the same way as their UK peers.
The regulations require SLPs which are in existence before July 24 2017 to deliver the details of PSCs by August 7 2017.
A PSC is someone who holds the right to more than 25 percent of the SLP’s surplus assets on winding up; holds more than 25 percent of voting rights; holds the right to appoint or remove the majority of the persons who are entitled to take part in the management of the SLP; or has the right to exercise or exercises significant influence or control over it.
“PSCs would likely include the general partner, any appointed manager and any limited partner whose interest in the partnership represents more than 25 percent of total interests,” Proskauer said in a client note.
The EU’s fourth Anti-Money Laundering Directive, which specifically targets the “high risk” nature of private fund firms, came into effect last week. Firms have until June 2018 to be compliant, as reported by pfm.