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.