The recently published Money Laundering and Terrorist Financing (Amendment) (EU Exit) Regulations 2020 update the existing Money Laundering Regulations. The main changes introduce provisions relating to trusts, which includes providing for additional trusts to be included on the trust register and extending the duty to report discrepancies in beneficial ownership to trusts. Some of the provisions will come into force on 6th April 2021 and on 10th March 2022, and a few came into force on 6th October.

Although the Guidance will be amended as appropriate and where relevant, the following other minor changes are noted with effect from 6th October:

  • Regulation 33 (obligation to apply EDD) has been amended to specify duties on insurance firms in relation to beneficiaries of life insurance policies. A new paragraph 5.5.12 in Part I has been approved by the Board and may be found under the Revisions tab.
  • Regulation 34 has been amended to clarify that firms must apply certain enhanced due diligence measures to correspondent relationships only if they involve the execution of payments.
  • Regulation 28 (19)(b) has been amended to replace “an appropriate level of assurance” with “assurance to a degree that is necessary for effectively managing and mitigating any risk of money laundering and terrorist financing.”