FCA webpage on Ukraine and anti-money laundering obligations.

The FCA has published a new webpage reminding firms of their anti-money laundering obligations in light of recent EU asset freezes against certain individuals in response to events in Ukraine.

The webpage encourages firms to take steps necessary to ensure that they continue to meet legal and regulatory anti-money laundering and reporting requirements.

A reminder to FCA-regulated firms after developments in Ukraine

Developments in Ukraine have served to highlight the continuing need for vigilance and robust systems and controls in dealing with actual or potential politically exposed persons. Financial institutions should be aware of the possible impact these events may have on patterns of financial activity, when they assess risks related to particular customers and flows of funds.

We expect authorised firms to establish and maintain systems and controls to counter the risk they might be used to further financial crime. Firms must also comply with their legal obligations under the Proceeds of Crime Act 2002 and the Money Laundering Regulations 2007.

The regulations related to Politically Exposed Person (Regulations 14(4) and 20(2)) and transaction monitoring (Regulations 8 and 20) are particularly relevant in this context.

We expect firms to consider the impact of these developments on their anti-money laundering policies and procedures in a risk-based manner, and to take the steps necessary to ensure they continue to meet their legal and regulatory anti-money laundering and reporting obligations.

The EU has issued asset freezes against various individuals:

On 6 March 2014 the EU decided to issue asset freezes against certain members of the former Ukrainian government and their associates. EU Regulation 208/2014 lists those subject to this asset freeze.
http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2014:066:0001:0010:EN:PDF
On 17 and 21 March 2014 the EU decided to issue further asset freezes against certain individuals ‘in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine’.

THOSE listed to this asset freeze. EU Regulations