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.
All you want is a straight answer. Is this enough? Can I onboard this client? Can I accept this document? Is my EID provider running a tight ship or will I get sunk? Straight-talking fscom anti money laundering expert, Mike Southgate will give the straight answers at the next MLRO Masterclass.
Today’s consumer generally has a choice of banking providers. They get to call the shots while banks tow the line and play nicely for the good consumers.
Not so for payment or e-money institutions.
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: