On 15 May 2020, the Joint Money Laundering Steering Group (JMLSG) published a proposed new piece on Pooled Client Accounts in Part I Chapter 5 of its Guidance.
A Pooled Client Account (PCA) is a bank account opened with the firm by a customer, for example a legal practitioner or letting agent, to administer funds that belong to their own clients. Their clients’ money will be co-mingled but the customer’s clients will not be able to directly instruct the firm to carry out transactions.
Suspense accounts held by respondent institutions are not PCAs (refer to Part II Sector 16 on Correspondent Relationships).
There are two primary vectors of risk:
- The customer’s clients misuse a PCA without the knowledge of the customer; and
- The customer is complicit in using its PCAs for money laundering / terrorist financing purposes, either willingly or under duress
The deadline for comments is 10 June 2020.