On March 21, the UK’s Joint Money Laundering Steering Group (JMLSG) opened a consultation on (Consultation), and published proposed revisions (Proposal) to, Part I of its guidance on the prevention of money laundering and the financing of terrorism for the UK financial services industry (Guidance).
The JMLSG states that the Proposal:
- reflects the provisions of the proposed new Money Laundering, Terrorist Financing and Transfer of Funds Regulations 2017 (Regulations), which were published by HM Treasury on March 15;
- makes extensive changes to the material on electronic verification in chapter 5 of the Guidance. (This is to address concerns that the present text is not even-handed enough and does not reflect modern practices in the electronic/digital world);
- reorders material in chapter 4 of the Guidance, to present the separate text on risk assessment and the risk based approach more clearly. In light of the introduction in the new Regulations of a formal legal obligation to carry out a risk assessment, the JMLSG felt it was appropriate to improve the presentation of the supporting material in the Guidance; and
- is believed to be consistent with the as yet unpublished Risk Factor Guidelines, to be issued by the European Supervisory Authorities.
The Consultation closes on April 28, and the Proposal is available here.