The Joint Money Laundering Steering Group (JMLSG) has published proposed revisions to Part I of its guidance in line with the proposed Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (the new Regulations).
Part I of the JMLSG guidance covers:
- the importance of senior management taking responsibility for effectively managing the money laundering and terrorist financing risks faced by the firm’s businesses (chapter 1);
- appropriate controls in the context of financial crime (chapter 2);
- the role and responsibilities of the nominated officer and the money laundering reporting officer (chapter 3);
- adopting a risk-based approach to the application of customer due diligence (CDD) measures (chapter 4);
- helping a firm have confidence that it has properly carried out its CDD obligations, including monitoring customer transactions and activity (chapter 5);
- the identification and reporting of suspicious activity (chapter 6);
- staff awareness, training and alertness (chapter 7); and
- record keeping (chapter 8).
Whilst the JMLSG guidance has been aligned with the text of the new Regulations, the JMLSG has also made extensive changes to the material on electronic verification in chapter 5, in order to address concerns that the present text does not reflect the digital world. Material on the risk-based approach in chapter 4 has also been reordered to present more clearly the text on risk assessment, and the risk-based approach.
The deadline for comments on the draft JMLSG guidance is 28 April 2017.
View JMLSG publishes proposed revisions to Part 1 of its guidance, 21 March 2017