Anti-money laundering regulatory round-up

Author: Susannah Cogman

Late 2018 and early 2019 saw a flurry of regulatory developments and proposals relating to anti-money laundering. We have reported on these in brief in our regular corporate crime updates, but for those who have been – for example – too immersed in Brexit to read the underlying documents in detail, we have taken this opportunity to bring together an overview of, and commentary on, a number of recent anti-money laundering/counter-terrorist financing ("AML/CTF") developments. In particular, we discuss in this briefing:

• the FCA's report on data submitted in the first annual financial crime data return;
• recent developments in the EU's list of high risk third countries;
• amendments to compliance requirements in respect of anonymous safety deposit boxes;
• the FCA's thematic review on money laundering risks in the e-money sector;
• a Decision Notice issued by the FCA to a CEO for failings in his oversight of his bank's AML systems and inadequate supervision of the MLRO to whom he had delegated relevant responsibilities;
• proposals relating to money laundering supervision in the EU;
• the FATF's Mutual Evaluation Review of the UK;
• FATF guidance on a risk-based approach to the securities sector;
• other FATF developments of interest, in particular in relation to virtual assets;
• reform of the UK Suspicious Activity Reporting regime;
• a recent RUSI paper on the scale of money laundering in the UK;
• AML-related amendments to the Financial Crime Guide (FC), following consultation GC 18/1; and
• an overview of the current position regarding AML compliance post-Brexit, in the event of a no-deal exit.

Please click here to read our full briefing.