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
Money laundering
New briefing note – Money Laundering Controls in the Art Market
The UK art market is one of the biggest such markets in the world, second only to China and the US, attracting high value items from around the globe. Several unique features make the UK art market attractive to money launderers and those financing terrorism. As part of our Financial Crime Spotlight series, we have…
FCA publishes review findings on treatment of PEPs and launches guidance consultation


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…
FATF update on FATF Standards on VAs and VASPs

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…
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

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.