The Financial Regulator has issued Part I of the Draft Guidance Notes (dated March 2010) on the prevention of the use of the financial system for the purpose of money laundering and terrorist financing, and is seeking public comment on them.
The Guidance Notes are structured in two parts. Part I contains core guidance which provides generic guidance that is applicable to all financial services designated persons. Part II sets down additional supplemental guidance notes for specific sectors. The sectoral guidance notes are incomplete on their own and must be read in conjunction with the core guidance notes, which will be published in due course by the Financial Regulator.
The purpose of the Guidance notes is to provide guidance on the legislation and on how designated persons can meet their requirements, by, for example, implementing systems and controls. The Financial Regulator has flagged that the Guidance notes may change as the Criminal Justice (Money Laundering and Terrorist Financing) Bill 2009 passes through the legislative process. We expect this Bill to be passed shortly.