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Trust Services in the UK: STEP guidance

Last December the UK introduced a new prohibition on the provision of trust services to or for the benefit of Russian persons, in particular individuals ordinarily resident in Russia. These restrictions also apply in the islands of Jersey and Guernsey and the British Overseas Territories (including, inter alia, the British Virgin Islands).

In April, Society of Trust and Estate Practitioners (STEP) released updated guidance note on application of these restrictions. The most interesting examples are set out below:

👉 Do the restrictions apply to a trust where a beneficiary is a Russian citizen residing in the UK?

🔹 No, citizenship does not affect the application of British restrictions. However, designated persons (i.e. those included in the UK sanction lists) cannot receive trust services regardless of where they reside.

👉 A beneficiary of a trust who permanently resides in the UK travels to Russia for one week. Would they be considered "located" in Russia now?

🔹 No, but if the stay in Russia is extended, for example, for six months, the situation changes and the person may be considered "located" in Russia. Consequently, they start being subject to restrictions.

👉 Can a British citizen provide trust services while in France to Russian clients?

🔹 No. The territorial scope of the restrictions is worldwide, so all British citizens must comply with them regardless of their location, be it in France, the UAE, or any other country.

👉 A minor beneficiary of a trust resides in Russia. Are trust services available to them?

🔹 Yes, in such cases, there is an exception: trust services can be provided to beneficiaries under 18 years old (provided that the actual recipient of such services is not a designated person).

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