Clarinda Grundy

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JMLSG publishes provisional updates to Part II Guidance Trade Finance chapter

On 19 May 2021, the Joint Money Laundering Steering Group (JMLSG) published provisional updates to its Part II Guidance Trade Finance chapter (chapter 15). A number of the proposed changes clarify the definition of trade finance products/services, and how these can be used to facilitate global trade. In addition, material updates to the financial crime … Continue Reading

UK Government publishes Economic Crime Plan Statement of Progress

On 4 May 2021, the UK Government and UK Finance published a joint Statement of Progress against their Economic Crime Plan, covering the period from its launch in July 2019 to February 2021. The Plan was originally launched to help the UK tackle fraud and economic crime, and it is divided into 7 Strategic Priority … Continue Reading

Part 7: The Biden Presidency and new and improved anti-money laundering tools

2021 Financial crime Outlook series Senior management and boards are increasingly acknowledging the threat of financial crime as a critical risk to their business that must be addressed. This has been exacerbated in the last 12 months through the impact of the pandemic as well as rising domestic and international tensions. Our financial crime compliance … Continue Reading

FCA expands financial crime data return to almost three times as many firms

On 31 March 2021, the UK’s Financial Conduct Authority (FCA) published a Policy Statement which expands the scope of its annual financial crime data return (REP-CRIM) to almost three times as many firms from circa 2,500 to circa 7,000. New firms will be obliged to participate in REP-CRIM from 30 March 2022 onwards. Firms now … Continue Reading

Public consultation on FATF draft guidance on a risk-based approach to virtual assets and virtual asset service providers

On 19 March 2021, the Financial Action Task Force (FATF) issued a public consultation on proposed revisions to its 2019 guidance on the risk-based approach to virtual assets (VAs) and virtual asset service providers (VASPs). The FATF is proposing to update its guidance in order to: Clarify the definitions of VA and VASP to make … Continue Reading

Mitigating the unintended consequences of the FATF Standards

On 18 March 2021, the Financial Action Task Force (FATF) announced that in February it had launched a new project to study and mitigate the unintended consequences resulting from the incorrect implementation of the FATF Standards. The project will look at four areas: De-risking. Financial exclusion. Suppression of non-profit organisations (NPOs) or the NPO sector … Continue Reading

EBA consults on changes to its guidelines on risk-based AML/CFT supervision

On 17 March 2021, the European Banking Authority (EBA) issued a consultation paper setting out proposed changes to its guidelines on risk-based supervision of credit and financial institutions’ compliance with anti-money laundering and countering the financing of terrorism (AML/CFT) obligations. Article 48(10) of the Fourth Anti-Money Laundering Directive requires the EBA to issue guidelines to … Continue Reading

The FATF and Egmont Group publishes updated trade-based money laundering risk indicators

On 11 March 2021 the Financial Action Task Force (FATF) and Egmont Group published a joint report on trade-based money laundering (TBML) risk indicators. This follows on from a report published in December last year by the same bodies highlighting pertinent trends and developments with respect to TBML for market participants to be aware of. … Continue Reading

Part 5: The increasing emphasis of RegTech and FinTech in combating financial crime

2021 Financial crime Outlook series Senior management and boards are increasingly acknowledging the threat of financial crime as a critical risk to their business that must be addressed. This has been exacerbated in the last 12 months through the impact of the pandemic as well as rising domestic and international tensions. Our financial crime compliance … Continue Reading

FATF publish guidance to support global supervisors in implementing a risk-based approach to AML/CTF supervision

On 4 March 2021 the Financial Action Task Force (FATF) released new guidance aimed at supporting the application of a risk-based approach to anti-money laundering (AML) and counter terrorist financing (CTF) supervision. This builds on previous guidance released in 2015, but widens the scope of the guidance to enhance applicability to more recently AML regulated … Continue Reading

FATF consults on guidance relating to Proliferation Financing Risk Assessment and Mitigation

FATF consults on guidance relating to Proliferation Financing Risk Assessment and Mitigation On 2 March 2021, the Financial Action Task Force (FATF) launched a consultation aimed at private sector stakeholders in relation to guidance which the FATF is developing regarding risks associated with the financing of proliferation of weapons of mass destruction (proliferation financing). This … Continue Reading

Part 4: The Growing Importance of the Money Laundering Reporting Officer

2021 Financial crime Outlook series Senior management and boards are increasingly acknowledging the threat of financial crime as a critical risk to their business that must be addressed. This has been exacerbated in the last 12 months through the impact of the pandemic as well as rising domestic and international tensions. Our financial crime compliance … Continue Reading

Outcomes of the February 2021 FATF Plenary

The first quarterly Financial Action Task Force (FATF) plenary of 2021 took place over 22, 24 and 25 February 2021 to discuss developments with respect to anti-money laundering (AML) and counter terrorist financing (CTF). Delegates discussed a number of initiatives relating to FATF’s strategic priorities as well as the AML/CTF frameworks of specific jurisdictions. The … Continue Reading

Financial Crime Outlook: 2021 and beyond

Senior management and boards are increasingly acknowledging the threat of financial crime as a critical risk to their business that must be addressed. This has been exacerbated in the last 12 months through the impact of the pandemic as well as rising domestic and international tensions. Norton Rose Fulbright’s financial crime compliance specialists, located in … Continue Reading

Special Q&A report for Financier Worldwide Magazine: AML and sustainable compliance

AML as a focus area and point of discussion for many companies will never fade. If anything, the increasing pressure on companies and the  expanding list of companies which are caught or impacted by global legislative AML changes means that many will need to continually assess if their AML frameworks are not only adequate but … Continue Reading

Financial Crime Outlook: 2021 and beyond

Senior management and boards are increasingly acknowledging the threat of financial crime as a critical risk to their business that must be addressed. This has been exacerbated in the last 12 months through the impact of the pandemic as well as rising domestic and international tensions. Norton Rose Fulbright’s financial crime compliance specialists, located in … Continue Reading

UK Government publishes its 2020 UK National Risk Assessment (NRA) of money laundering and terrorist financing

On 17 December 2020, the UK Government published its 2020 UK National Risk Assessment (NRA) of money laundering and terrorist financing. The report follows on from the previous UK NRA published in 2017. The 2020 NRA reflects on the positive outcomes achieved by the UK in the Financial Action Task Force (FATF) Mutual Evaluation conducted … Continue Reading

The UK SAR Annual Report 2020 reflects continued increase in reports as well as crucial changes in the UK’s reporting framework

In November 2020 the UK’s Financial Intelligence Unit (UKFIU) within the National Crime Agency (NCA) published its Suspicious Activity Reports (SAR) Annual Report 2020 (here) covering the period April 2019 to March 2020. The report indicates a continued increase in SARs submitted to the NCA (a 20% increase from the previous period). In addition, similar … Continue Reading

UK Government updates anti-money laundering legislation in preparation for the upcoming conclusion of the Brexit transition period

In October 2020 the UK Government published The Money Laundering and Terrorist Financing (Amendment) (EU Exit) Regulations 2020 which amend The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR17). Whilst some provisions within this new regulation came into force on 6 October, others will not take effect until … Continue Reading

EBA sets out how prudential supervisors should take money laundering and terrorist financing risks into account in the Supervisory Review and Evaluation Process

On 4 November 2020, the European Banking Authority (EBA) issued an opinion setting out how prudential supervisors should consider money laundering and terrorist financing risks in the context of the Supervisory Review and Evaluation Process (SREP). With this opinion, the EBA calls on prudential supervisors to take into account money laundering and terrorist financing (ML/TF) … Continue Reading

FATF October 2020 plenary: impacts of Covid-19 on AML and CTF; considerations for near-term future FATF assessments; and focus on the financing of the proliferation of weapons of mass destruction

On 21 to 23 October 2020, the Financial Action Task Force (FATF) held its final quarterly plenary of 2020 as a virtual event. The discussions over three days mostly focussed on Strategic Initiatives reacting to the Covid-19 pandemic and progress made on country specific processes. The FATF also provided an update on their strategic focus … Continue Reading

CCAB publishes AML guidance targeted at the accountancy sector

On 30 September 2020, the Consultative Committee of Accountancy Bodies (CCAB) published updated anti-money laundering (AML) and counter terrorist financing (CTF) guidance targeted at the accountancy sector. This updated guidance reflects the changes made to the UK’s Money Laundering Regulations with respect to the provisions of the 5th EU Anti-Money Laundering Directive, and aims to … Continue Reading

FATF report – virtual assets red flag indicators of money laundering and terrorist financing

On 14 September 2020, the Financial Action Task Force (FATF) published a report, Virtual Assets – Red Flag Indicators of Money Laundering and Terrorist Financing. The report is based on more than 100 case studies and is designed to help national authorities and financial institutions identify potential money laundering and terrorist financing activity involving virtual … Continue Reading

Risk Consulting Hot Topic Series: Financial Crime

The financial crime landscape has evolved significantly in recent years through, for example, the implementation of the 4th and 5th EU Anti-Money Laundering Directives; diversification of scope of financial crime to include linked disciplines like tax evasion and market abuse; and rapid developments of new technology. Further regulatory changes are also on the horizon, including … Continue Reading
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