JMLSG consults on guidance changes: JMLSG is consulting on various changes to its guidance. The changes do not anticipate the fourth Money Laundering Directive, and JMLSG will need to revise the guidance again to account for it in due course. However, it has identified several aspects of the current guidance that would benefit from changes.  The consultation includes a marked up version of parts 1 and 2 of the guidance, showing the changes. Key proposed changes include:

  • tying in references to FCA's financial crime prevention objectives and to the Financial Crime Guide;
  • stressing the importance of communication;
  • giving guidance on how to assess the effectiveness of systems and controls;
  • emphasising the different roles of the Nominated Officer and MLRO;
  • giving further guidance on risk assessment;
  • stressing the need to consider a customer's contacts and relationship with other parts of the business; and
  • putting better context on enhanced due diligence requirements.

JMLSG asks for comments by 15 September. (Source: JMLSG Consults on Guidance Changes)