On 9 July 2024, the Financial Action Task Force (FATF) published a report which provides the latest update on jurisdictions’ compliance with FATF’s Recommendation 15 and its Interpretative Note. In 2019 Recommendation 15 was updated to apply anti-money laundering and counter-terrorist financing (AML/CFT) measures to virtual assets (VAs) and
Money laundering
FCA postpones publication of review findings on treatment of PEPs
On 19 June 2024, the Financial Conduct Authority (FCA) published an update on its review of the treatment of domestic Politically Exposed Persons (PEPs) by financial services firms.
The FCA explains that it had been on track to publish the findings from this review (which was launched in September 2023)…
Published in OJ – Directive on cross-border law enforcement access to bank account registries
On 19 June 2024, there was published in the Official Journal of the EU (OJ), Directive (EU) 2024/1654 of the European Parliament and of the Council of 31 May 2024 amending Directive (EU) 2019/1153 as regards access by competent authorities to centralised bank account registries through the interconnection system and technical measures to…
Published in OJ – AML Regulation, MLD 6 and AMLA Regulation
On 19 June 2024, there was published in the Official Journal of the EU (OJ),
…Failure to prevent fraud ‘reasonable procedures’ guidance to be published early summer
The government have confirmed that the guidance in relation to what constitutes ‘reasonable procedures’ for the prevention of fraud is likely to be published in ‘early summer’, meaning that the new Failure to Prevent Fraud Offence would come into force by the end of the year.
See here for our article summarising the new offence…
Failure to prevent fraud: what do I do now? Part 1: Risk assessments
Many companies are currently considering what steps they need to take in relation to the new UK failure to prevent fraud offence (which is expected to come into force later this year or in early 2025).
By way of recap, a company will be liable for failing to prevent fraud by its associated persons (e.g.
JMLSG consults on proposed revisions to Sector 18 (Wholesale markets) in Part II of its Guidance
On 30 April 2024, the Joint Money Laundering Steering Group (JMLSG) published for consultation its proposed amendments to Sector 18 (Wholesale markets) in Part II of its Guidance.
The deadline for comments on the proposed revisions is 1 July 2024.
Upcoming webinar: Investigations in EMEA – Horizon scanning
On Tuesday 16 April 2024, please join us for a webinar where our team from across EMEA will discuss the key recent and upcoming trends in financial crime legislation and regulatory enforcement in the EU, UK and Singapore.
This webinar will highlight important changes to anti-money laundering regulation and wider financial crime legislation in the…
Status of implementation of Recommendation 15 by FATF Members and jurisdictions with materially important VASP activity
On 28 March 2024, the Financial Action Task Force (FATF) published a table setting out the status of the implementation of Recommendation 15 by FATF members and other jurisdictions with the most materially important virtual asset service provider activity. The table follows a stocktake of current levels of implementation across the global network.…
Wolfsberg Principles for Auditing Financial Crime Risk Management
On 27 March 2024, the Wolfsberg Group (Group) published Principles for Auditing Financial Crime Risk Management (FCRM) using the Wolfsberg Factors (Factors) which were published in 2019.
The Group notes that internal audit (IA), an independent function within a financial institution (FI), constitutes the third…