Money laundering

The growth of the UK gambling market, in particular online, has brought with it new opportunities for exploitation by criminals. Awareness of the way in which criminals may seek to use operators to launder the proceeds of crime and robust controls to prevent this is therefore key. As part of our Financial Crime Spotlight series

On 18 July 2024, the Financial Conduct Authority (FCA) published the results of its multi-firm review on the treatment of politically exposed persons (PEPs), and launched a consultation (GC24/4) on proposed changes to its guidance on the subject.

Background

Financial services firms are required (under the Money Laundering, Terrorist

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

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)

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

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

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.