FIN.

JMLSG consults on Part 1 amendments

The JMLSG is consulting on changes to various parts of Part 1 of its guidance. The changes relate to:

  • in chapter 5
    • new provisions on local authorities and professional deputies appointed by the Court of Protection or equivalent;
    • new paragraphs relating to group companies – saying that firms should apply a risk-based approach where establishing a business relationship or carrying out an occasional transaction for a group company;
    • changes and additions to the guidance on intermediaries as agents of the customer – including guidance that, where an underlying party is a low risk customer, the firm may apply SDD; and
  • in chapter 2, changes and new text relating to outsourcing, including new guidance that the MLRO/SMF 17 must have authority to take action where AML/CTF risks arise in intragroup outsourcings and recommendations for the minimum content of an SLA for an intragroup outsourcing.

The JMLSG asks for comment by 28 March.

Emma Radmore