Saturday 15th December 2018
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Comsure operates in:the UK, Jersey, Guernsey

Comsure AML Bulletin – Autumn 2017 update on AML training

The following provides updates on anti-money laundering and counter-terrorist financing developments, both in the UK and internationally, that Comsure has included in its training for the period from May 2017 to October 2017

The Highlights include:
1. PUBLICATION OF MONEY LAUNDERING REGULATIONS 2017
a. The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLRs 2017) came into force on 26 June 2017 and are the means by which the UK government transposed and implemented the Fourth Money Laundering Directive. The MLRs 2017 include obligations relating to necessary risk assessments and customer due diligence provisions, as well as information on the duties of supervisory authorities and beneficial ownership registers.

2. FCA PUBLISHES FINAL GUIDANCE ON TREATMENT OF POLITICALLY EXPOSED PERSONS FOR AML PURPOSES
a. The FCA published its finalised guidance on the treatment of politically exposed persons for anti-money laundering purposes on 6 July 2017. The guidance provides advice on how firms can meet their obligations when opening new business relationships or monitoring existing ones. Firms are expected to take appropriate but proportionate measures in meeting their obligations.

3. REPORT ON THE RISKS OF MONEY LAUNDERING AND TERRORIST FINANCE AFFECTING THE INTERNAL MARKET AND CROSS-BORDER ACTIVITY
a. The European Commission published a report on 26 June 2017 assessing the risks of money laundering and terrorist finance (ML/TF) affecting the internal market and cross-border activities. The report is the first one on this topic to be carried out at a supranational level in the EU and aims to identify circumstances in which the services and products delivered or provided could be abused for ML/TF purposes.

4. FCA PUBLISHES ANTI-MONEY LAUNDERING ANNUAL REPORT FOR 2016/2017
a. In its fourth AML annual report, the FCA sets out how it has sought to achieve its AML objectives for the past year. Key topics include developments in AML supervision strategy, findings and outcomes from recent specialist supervision work, the impact of new technology on streamlining AML processes and a forward-looking review of the FCA’s supervision strategy.

5. OFFICE OF FINANCIAL SANCTIONS IMPLEMENTATION IDENTIFIES HIGH-RISK COUNTRIES WHERE ENHANCED DUE DILIGENCE IS REQUIRED
a. On 26 June 2017, the Financial Action Task Force issued an advisory notice identifying countries with strategic deficiencies in their anti-money laundering and counter-terrorist financing regimes. It is expected that firms will apply enhanced due diligence measures concerning those entities associated with the countries named in the report.

6. PUBLICATION OF PEOPLE WITH SIGNIFICANT CONTROL (AMENDMENT) REGULATIONS 2017
a. The Information about People with Significant Control (Amendment) Regulations 2017 came into force on 26 June 2017 and introduced changes required under article 30 of the Fourth Money Laundering Directive. Stricter timescales have been imposed on firms for updating the People with Significant Control (PSC) register. The scope of the exemption about maintaining a PSC register has also been reduced.

For more information on Comsure AML training please contact mathewbeale@comsuregroup.com


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