Changes made by Money Laundering Regulations 2017

New blog post discusses some of the MLR 2017 changes

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I have written a new blog post on (to give them their full title) The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, which came into force on 26 June 2017.

The new regulations in their final version are over 100 pages, so I have restricted myself to commenting on the hierarchy of risk assessments, written policies controls and procedures, changes for High Value Dealers and for Estate Agents, the new definition of a PEP and the banning of persons with criminal convictions.

The new regulations will affect every business within the 'regulated sector' to some extent.  At a minimum they will require new written policies and procedures and updated risk assessments - for a handful of people their impact may be life changing.  But the fundamentals from the 2007 Regulations remain in place.

You can see the blog article HERE.

An interesting quirk for accountancy firms which are incorporated is that, under Regulation 43, clients may now request a statement of information from the firm - covering legal and beneficial ownership and the firm's articles of association.  Where such information has been requested and (while the person who made the request remains a client) there is a change in any of the relevant particulars, the firm will be required to send updated information to that client / those clients within 14 days.


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the sea otter
By memyself-eye
26th Jun 2017 10:25

thank you David - who would now be an estate agent!

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By legerman
30th Jun 2017 14:42

Hi David

In your blog you state "It is not clear, to me at least, whether this will affect persons who have old offences which would be regarded for most purposes as ‘spent’ under the Rehabilitation of Offenders Act 1974." HMRC have issued guidelines on approval status for accountants etc, and it only relates to unspent convictions AFAICT

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