The JMLSG is consulting on various changes to Part I of its guidance in anticipation of the upcoming changes to the MLRs. The changes affect:
- para 2.9 in relation to clarifying what “unusually” means;
- para 5.2.4A in relation to the bank insolvencies exception;
- para 5.3.142 and Annex %-V on pooled client accounts; and
- paras 5.3.94A and 5.3.88 on identifying a person who is acting on behalf of another.
Consultation closes on 29 June.