Wolfsberg Group responds on MLR review

The Wolfsberg Group has responded to the Treasury consultation on improving the effectiveness of the MLRs. Among the key points in its detailed submission are:

• that an effective AML/CTF framework includes discontinuing low-impact compliance activity so as to redirect resource to areas of higher value in deterring financial crime;
• a recommendation to enhance the risk-based approach in several specific ways, including
  • replacing the requirement always to conduct EDD on “grey list” country customers and UK PEPs with a requirement to assess and respond to the risk of the specific customer; and
  • replacing the current broadly described higher risk factors with a focus on responding to national threat priorities;
• strengthening system co-ordination in several specific ways including positioning the NRA as a baseline for all firms’ risk assessments and delivering Companies House reform,

The response says that, with the new round of FATF mutual evaluations approaching, the UK has a real opportunity to improve the effectiveness of its regime.