The US government announced that it continues to pause mandatory beneficial ownership information filing requirements with the Financial Crimes Enforcement Network, despite the Supreme Court of the United States granting the government’s motion to stay a nationwide injunction issued by a Texas federal judge. Read our alert here.
Money laundering
The Financial Services and Markets Act 2023 (Digital Securities Sandbox) (Amendment) Regulations 2025


On 30 January 2025, the Financial Services and Markets Act 2023 (Digital Securities Sandbox) (Amendment) Regulations 2025 were laid before Parliament and published on legislation.gov.uk, along with an explanatory memorandum.
The Regulations amend the Financial Services and Markets Act 2023 (Digital Securities Sandbox) Regulations 2023 (the DSS Regulations), to modify the effect of…
FCA publishes multi-firm review findings on firms’ use of the NFD and money mule account detection tools


On 23 January 2025, the Financial Conduct Authority (FCA) published the key findings from its multi-firm review on payment services and account providers’ use of the National Fraud Database (NFD) and money mule account detection tools to tackle risks associated with money muling activities.
Background
The FCA explains that money muling…
FCA and PSR set out the next steps for open banking


On 23 January 2025, the Financial Conduct Authority (FCA) and the Payment Systems Regulator (PSR) set out the next steps for open banking.
The regulators note that there was significant progress in developing open banking in 2024 as a result of voluntary funding from 20 leading firms. Those developments included:…
FCA publishes updated analysis on money laundering through the markets risk


On 23 January 2025, the Financial Conduct Authority (FCA) published updated analysis on money laundering through the markets (MLTM) risk – i.e. the use of capital markets to move criminally generated cash, so it appears legitimately generated.
The FCA focused on wholesale brokers in its review because of their important role…
FMSB Final Standard for Client Onboarding

On 19 December 2024, the Financial Markets Standards Board (FMSB) published as final its Standard for Client Onboarding: Documentation and Processes and Annexes.
The Standard has been drafted to allow onboarding firms to continue to fully apply the UK’s Risk Based Approach to know-your-customer and provides more granular, documentary guidance for the practical implementation…
EBA report on the functioning of AML/CFT colleges

On 16 December 2024, the European Banking Authority (EBA) issued its fourth report on the functioning of anti-money laundering and countering the financing of terrorism (AML/CFT) colleges.
The report sets out findings and observations from EBA staff’s monitoring of AML/CFT colleges in 2023, which suggest that, overall, Member State competent authorities…
EBA publishes findings from its fourth and final round of reviews of NCAs approaches to tackling ML/TF risks

On 13 December 2024, the European Banking Authority issued a press release stating that it had published the findings from its fourth and final round of reviews of Member State competent authorities’ (NCAs) approaches to tackling money laundering and terrorist financing risks in the banking sector. With this round, the EBA has now…
HMT publishes updated guidance on money laundering and high risk third countries


On 19 November 2024, HM Treasury (HMT) published an updated version of its guidance, Money Laundering Advisory Notice: High Risk Third Countries.
The guidance contains advice issued by HMT about risks posed by jurisdictions with unsatisfactory money laundering and terrorist financing controls.
In the November update, the guidance has been amended to…
FATF publishes Money Laundering National Risk Assessment Guidance
On 7 November 2024, the Financial Action Task Force (FATF) published its Money Laundering National Risk Assessment Guidance.
The Guidance is intended to support countries in conducting a National Risk Assessment (NRA) focused on the assessment of money laundering risks. FATF explains that the Guidance serves as a practical resource…