AML Update

Firms, and MLROs in particular, should be aware that HM Treasury has updated its advisory notice on problem jurisdictions where Enhanced Due Diligence (EDD) is advised and where firms may wish to apply EDD.

The advisory notice informs us that the assessments were based upon the pre-2012 revised FATF Recommendations. The previous FATF Recommendations were based upon “40 + 9”, being the original 40 recommendations to counter money laundering to which were added a total of 9 further recommendations to counter terrorist financing. The revision amalgamated the two sets of recommendations so that we are back to 40 recommendations.

FATF has also updated its Guidance on AML/CTF.