I am writing to update you on the implementation of the 4th Anti Money Laundering Directive. As you know, the government’s intention has always been to achieve the transposition date of 26th June. Recent events have made this timetable more challenging, and the regulations are still subject to Parliamentary approval. Nevertheless, we continue to anticipate that the implementation will go ahead as planned, and hope to be in a position to confirm this later in the week.
Assuming all of the above, the transitional arrangement will be based on date of receipt of the submission. CS01 submissions received on or after the 26th June 2017 must be via the new schema. From the 26th June all PSC updates must be made via event driven submissions (PSC01-09 or their LLP equivalents). This is the case even if a change is dated prior to the 26th June 2017. The cut off period being midnight on Sunday 25th June.
I hope this clarifies.
SDN