Samantha Morgan contributes to STEP & TACT guidance on FATCA and CRS changes for trusts

We are pleased to share that Samantha Morgan, Partner at RMW Law, has helped to draft a newly published STEP and TACT guidance note on changes to FATCA and CRS registration requirements for trusts that are Reporting Financial Institutions or Trustee-Documented Trusts.

The guidance, published in December 2025, addresses recent regulatory developments affecting trust registration and ongoing compliance under the automatic exchange of information (AEOI) regime. It provides practical commentary for trustees and advisers on classification, registration obligations and the steps required to ensure compliance with the updated rules.

The note was written by Samantha Morgan, alongside Imogen Davies and Mark Coates of Withers LLP, and Scott Clayton of TACT. Samantha’s contribution reflects her recognised expertise in trust regulation, reporting obligations and cross-border compliance, and her active role in shaping industry guidance on evolving international standards.

The guidance will be of particular interest to trustees, family offices and advisers responsible for the administration and reporting of complex trust structures.

If you would like to discuss the implications of these changes or how they may affect your trust arrangements, please contact Samantha Morgan or a member of RMW Law’s Private Client team.

Read the guidance note here:
https://www.step.org/system/files/media/files/2025-12/STEP-Guidance-Note-AEOI-Trust-Registration-December-2025-v2.pdf