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The European Supervisory Authorities have published final guidelines that set out factors that firms should consider when assessing the money laundering and terrorist financing (ML / TF) risk associated with a business relationship or occasional transaction. They also set out how firms should adjust the extent of their customer due diligence measures in a way that is commensurate to the ML / TF risk they have identified.…
In March and May 2017 the Joint Money Laundering Steering Group (JMLSG) published for consultation proposed revisions to its guidance in order to align it with the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017. In addition, in June 2017 the JMLSG proposed revisions to its sectoral guidance on electronic money. Our blogs are here, here and here.…
The Government has laid before Parliament The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (SI 2017 No. 692), which will come into force on Monday, 26 June 2017.…
The FCA has published Consultation Paper 17/13: Fourth Money Laundering Directive and Fund Transfer Regulation implementation (DEPP and EG) (CP17/13). On 15 September 2016, HM Treasury published its consultation paper on the transposition of the Fourth Money Laundering Directive (4MLD) and the Fund Transfer Regulation (FTR). On 15 March 2017, HM Treasury published a further consultation together with the draft implementing regulations, the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer)…
The Joint Committee of the European Supervisory Authorities (ESAs) has issued a joint consultation paper on draft regulatory technical standards (RTS) on the measures credit institutions and financial institutions shall take to mitigate the risk of money laundering and terrorist financing where a third country’s law does not permit the application of group-wide policies and procedures. Article 8 of the Fourth Anti-Money Laundering Directive (4MLD) requires entities subject to it (known as ‘obliged entities’) to…
The Wolfsberg Group (the Group) has published updated guidance as to how financial institutions should handle the money laundering risks posed by politically exposed persons (PEPs). This updates the guidance that the Group initially issued in 2003 and the FAQs issued in 2008. The updated guidance lays out what the Wolfsberg Group considers to be the most effective way of managing PEP risk, which is to position the PEP control framework as part of the…