The amendments were published the HMT response to its consultation on improving the effectiveness of the MLRs, and include:
➡️ Mandated EDD on transactions or customer relationships involving a person established in a FATF Call for Action country (the ‘black list’), not a FATF Increased Monitoring List country (the ‘grey list’);
➡️ EDD will be required on ‘unusually complex’ transactions instead of all complex transactions;
➡️ Further guidance will be published on the use of digital identities for ID&V;
➡️ Introducing new CDD requirements on pooled client accounts; and
➡️ Strengthened system collaboration including an expanded list of ‘relevant authorities’.
✅ Firms regulated by the MLRs should review the forthcoming changes and prepare for their operational impacts, including required revisions to current policies, controls, and procedures.
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