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The ink is barely dry on 4MLD, but it's time to consider 5MLD already.

[fa icon='calendar'] 14-Jul-2017 13:11:13 / by Mike Southgate posted in AML Assurance, 4MLD, 5MLD

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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.  

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