JMLSG consults on wholesale market guidance update

The JMLSG is consulting on changes to chapter 18 in Part II of its guidance, for wholesale markets. The changes generally update references, and:

  • clarify that as market abuse is a predicate offence, settlement of certain trades could represent placement for money laundering purposes;
  • include a new section on CDD in relation to authorised personnel acting on behalf of a customer;
  • note the importance of sanctions checks and appropriate OFSI reports in relation to securities, which are lower risk for AML purposes;
  • highlight the dangers of tax evasion risks of structuring bespoke cross-border transactions in a way that constitutes dividend arbitrage; and
  • add a section on wholesale subscription finance in private capital funds.

Consultation closes on 1 July.

Emma Radmore