Emma RadmoreThe 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.