Risk assessments have been a part of the EU Anti Money Laundering landscape for some time now and while 4MLD brought to the fore the need to have documented risk assessments, they are by no means a new concept.
The reason is that some of the provisions in the current draft have the potential to be a headache to implement. I don't mean the reductions in Simplified Due Diligent thresholds, or the stronger due diligence needed for payments to the EU listed high risk countries (though these are fairly significant) instead I am talking about article 32.
Is your firm prepared for 4MLD?
If not, you only have this weekend to get sorted and while we have had draft versions and a consultation JMLSG guidance in circulation for some time now, the new Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLRs 2017) are were finally laid before Parliament yesterday, and will come into force on Monday, meeting the 4MLD implementation deadline of 26 June.
The FCA do not want to regulate specific technologies.
Payment and e-money institutions must be ready to include additional information with wire transfers by the end of this month, with the new Wire Transfer Regulations (WTR2) (also known as the Fund Transfer Regulation, FTR) coming into effect on the 26 June.
After several weeks of reviewing the new draft legislation implementing the new anti money laundering directive and the Consultation JMLSG guidance, here is my detailed breakdown of the changes that were due to come our way.
At fscom, it's our job to keep you in the know, so we just wanted to send you a reminder of your anti-money laundering responsibilities under the Fourth Money Laundering Directive (4MLD). Here are the two key points to be aware of: