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JMLSG revised Guidance

After reviewing comments received on the consultation version of amendments to its Guidance published in March and April, JMLSG today publishes final revised Guidance, which will shortly be submitted to HM Treasury for Ministerial approval.

The final, revised Guidance is available here:

Part I
Part II
Part III

The revised Guidance reflects the provisions of the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017. It also takes account of the draft Risk Factor Guidelines published by the European Supervisory Agencies in October 2015, which have not yet been published in final.

Comments were received from 21 respondents in relation to Part I; 14 in relation to Part II; and 12 in relation to Part III. Comments covered matters of interpretation of aspects of the Regulation and the format and consistency of the text – all of which were addressed and changes made if felt appropriate, along with a number of clarificatory and other minor changes suggested by respondents - as well as more substantive areas. Principal in the latter category was the issue of electronic identification, where there were a number of requests for more recognition to be given to the use of digital identity. In addition, a number of commentators asked that some of the sectoral guidance in Part II should be significantly revised, in order to reflect more completely the current position in some business areas. Some commentators also felt that some of the text in Part III did not go into sufficient detail on compliance with the UK financial sanctions regime.

After careful consideration, the Board concluded that - given the unexpectedly late pressure to publish Guidance aligned with the Regulations transposing 4MLD, against a very short timetable – priority should be given to revising the Guidance for this purpose, and that wider, more substantive issues should be addressed later in the year, when there would be an opportunity for wider pre-exposure consultation. On Part III, the Board strongly feel that the guidance relating to the financial sanctions regime was not intended to be a complete analysis of the subject, but was a guide to how firms should approach this – so only minor amendments and updating have been made.

Versions of the final Guidance, marked up from the consultative text, are available here:

Part I
Part II
Part III

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