On 20 December the FCA published their amendments to the Money Laundering Regulations 2017, MLR5 with a 3 week deadline, well 2 weeks if you factor in the inevitable staff shortages over the Christmas period… in which firms must become compliant (10 January 2020).
Fear not. The mighty teeth of the FCA won’t come crushing down on you right away. Provided firms are able to show that they have taken “sufficient steps [towards becoming compliant]” phew…
In Summary, MLR5 introduces the following changes to the existing legislation:
- New additional high-risk factors when evaluating the need for EDD, and seek additional information and monitoring in certain cases, such as when there are relevant transactions between parties based in high-risk third countries.
- Firms must comply with reduced e-money thresholds when carrying out CDD.
- Ensure greater accuracy of their records relating to the beneficial ownership of corporate clients. They also need to understand the ownership and control structure of their corporate customers, and record any complications encountered in identifying beneficial ownership.
- Report to Companies House, any discrepancies between the information they hold on their customers compared with the information held in the Companies House Register.
For further information on MLR5 please refer to the following FCA Article.