We have responded to H M Treasury’s further consultation on the proposed changes to the Trust Registration Service (TRS) which was published last month in order to test whether the draft legislation transposes the Fifth Money Laundering Directive (5MLD) in a proportionate way. While the latest consultation provides some clarification on which ‘express trusts’ will be required to register, further guidance is required on a number of issues, including the requirement to register for non-EEA trusts entering a business relationship with a UK obliged entity and how access to the register will be policed. You can read our full response here.