Concerns had been expressed that the Directive might be implemented in a way that would apply increased and onerous identification requirements to beneficial owners of rights under occupational pension schemes.
The Directive has now been implemented by the Money Laundering Regulations 2007 (SI No 2007/2157). The Treasury had been made aware of the concerns amongst the industry about this issue as they drafted the regulations. These now state that pensions products that allow assignment under S44 of the Welfare and Pensions Act 1999 and S91 of the Pensions Act 1995 now qualify for Simplified Due Diligence - ie there is no requirement to identify the beneficial owner. Regulation 13 (7) (c) in the final Regulations refers.
