The DWP issued a call for evidence in October on the advice requirement and overseas transfers. The PLSA responded to this consultation, highlighting the following beliefs regarding future policy on overseas transfers: 

• Making it easier for UK residents to transfer their pensions overseas risks running counter to the Government’s own agenda on tackling scams. Any new policy in this area should take full account of the challenge of tackling scams (which should be the first priority) and should be coordinated with the DWP and HMT’s consultation on scams.
• There might be a case for doing something in the specific case of people already resident overseas, so they do not have to get two lots of IFA advice. But the Government must be careful not to create a new loophole whereby UK residents claim to live overseas in order to use an overseas IFA, perhaps provided by the scammer.
• The due diligence run by schemes to facilitate transfers is already very complex, and in the case of overseas transfers takes place in a vacuum of information. Therefore, any additional requirements for schemes to run due diligence on residency or the authenticity of advice from local advisers in different jurisdictions would not only increase this complexity but also increase their liability.

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