On 21 March 2017, the Joint Money Laundering Steering Group (JMLSG) published proposed revisions to Part I of its guidance on the prevention of money laundering and the financing of terrorism for the UK financial services industry. The revisions are set out in the following marked-up versions (all dated 14 March 2017):
- Chapters 1-3 (Senior Management responsibility and governance, Internal controls and Nominated Officer/money laundering reporting officer (MLRO)). http://bit.ly/2oZQZYE
- Chapter 4 (Risk-based approach). http://bit.ly/2nJe3dT
- Chapter 5 (Customer due diligence). http://bit.ly/2nJ8ZGt
- Chapters 6-8 (Suspicious activities, reporting and data protection, Staff awareness, training and alertness and Record-keeping). http://bit.ly/2nWS6ZI
A webpage on the consultation paper states that the proposed revisions: http://bit.ly/2oC1hBJ – each chapter is also shown;
- Chapters 1-3 click here http://bit.ly/2oZQZYE
- Chapter 4 click here http://bit.ly/2nJe3dT
- Chapter 5 click here http://bit.ly/2nJ8ZGt
- Chapters 6-8 click here http://bit.ly/2nWS6ZI
- The JMLSG has also published a draft version of the guidance taking into account the changes above. For the consultation version of Part I: click here
The Changes;
- Reflect the provisions of the proposed new Money Laundering, Terrorist Financing and Transfer of Funds Regulations 2017, which were published by HM Treasury on 15 March 2017
- Make 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.
- Re-orders a lot of the material in Chapter 4 of the guidance.
- This is to present the separate text on risk assessment and the risk based approach more clearly.
- In the light of the introduction of 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.
The consultation closes on 28 April 2017.