JMLSG consults on discrepancy reporting changes

JMLSG is consulting on changes to Part I of its Guidance to:

  • take account of amendments to the law relating to discrepancy reporting: the changes include specifying information firms should obtain and sets out a risk-based approach for obtaining appropriate register excerpts as part of ongoing monitoring. It also notes that material discrepancies should be considered with an overarching requirement of proportionality and reasonableness, and that a discrepancy itself does not necessarily mean the customer cannot be onboarded or that the firm must exit an existing relationship ; and
  • amend the guidance in Chapter 5 relating to impersonation risk. The guidance now explicitly suggests that firms should consider using biometric data including facial recognition as a means to managing risk by linking the customer directly to the claimed identity.

Consultation closes on 26 June.

Emma Radmore