Money laundering

On August 28, 2024, the Financial Crimes Enforcement Network (FinCEN) issued a final rule that will impose new anti-money laundering and countering terrorism financing (AML/CFT) program requirements on registered investment advisers and exempt reporting advisers (collectively, Covered IAs) by, among other things, including Covered IAs within the definition of “financial

The UK failure to prevent fraud offence has been long awaited. We are receiving a number of queries from clients about when the UK government’s “reasonable procedures” guidance is due to be published, when the offence will come into force and what they should be doing now to prepare.

In short:

  • we expect the “reasonable

This is the third article in our series breaking down the steps that organisations will need to take to put in place “reasonable procedures” to prevent fraud. Our previous posts, focusing on how to conduct effective fraud risk assessments and enhance polices and procedures, can be found here and here

The new UK failure

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 4 July 2024, the European Banking Authority (EBA) issued new guidelines on the ‘travel rule’.

The EBA publicly consulted on a draft version of the guidelines between 24 November 2023 and 26 February 2024. A public hearing took place on 17 January 2024.

The guidelines specify which information should accompany a transfer

On 26 June 2024, the European Banking Authority (EBA) issued a press release welcoming the entry into force of the new EU anti-money laundering framework.

The press release adds:

  • The EBA will retain its anti-money laundering / countering the financing of terrorism (AML/CFT) powers and mandates until December 2025 to minimise