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AML the essentials, issue 22 contains new government consultations, guidance on engaging in financial activity in Afghanistan, new SARs resources and an inside look at the roles of experienced Money Laundering Reporting Officers (MLROs).

High-risk third countries

Money Laundering Regulations (MLR17) require the UK regulated sector to apply enhanced customer due diligence in relation to high-risk countries. The government has published Money Laundering and Terrorist Financing (Amendment)(No.2)(High-Risk Countries) Regulations 2021 which substitutes the list of high-risk third countries specified in Schedule 3ZA of MLR17 with a new list. The updated list replicates those countries included by the Financial Action Task Force in their ‘Jurisdictions under Increased Monitoring’ and ‘High-Risk Jurisdictions subject to a Call for Action’ public documents.

Call for Evidence: Review of the UK’s AML/CTF regulatory and supervisory regime

The Government is seeking your views on the systemic effectiveness of the UK’s anti-money laundering (AML) and counter terrorist financing (CTF) regulatory and supervisory regimes and how they contribute to the overarching objective of countering economic crime. 

Consultation: Amendments to Money Laundering Regulations

The Government is also consulting on a set of amendments that will allow time-sensitive updates to the MLRs, which are required to ensure that the UK continues to meet international standards set by the Financial Action Task Force, whilst also strengthening and ensuring clarity on how the anti-money laundering regime operates. 

Guidance on engaging in financial activity in Afghanistan

OFSI has issued an alert to businesses setting out a reminder that within the Taliban, there are a number of sanctioned individuals and that UN sanctions are already in place against individuals and entities associated with the Taliban.

Given this heightened risk context, those engaging or considering engaging in any financial activity in relation to Afghanistan should:

  • consider conducting enhanced due diligence including in respect of entities that may be owned or controlled by designated persons
  • check the consolidated list and consider seeking independent legal advice before undertaking any activity

Members of the Taliban are listed under the UN Afghanistan regime. Individuals and entities with links to the Afghan Taliban are also listed under the ISIL (Da'esh) and Al-Qaida sanctions regime

Disciplinary update: August 2021

Read about recent cases where we have taken disciplinary action against ICAEW member firms and ICAEW members. 

SARs disclosures in civil litigation cases

The Government has published Circular 004/2021 ‘Money laundering: the confidentiality and sensitivity of suspicious activity reports (SARs) in the context of disclosure in private civil litigation. It sets out the Governments position on the use of SARS in private civil litigation matters and provides guidance to help protect reporters of SARs, the subject of SARs and the integrity of the SARs regime. Firms should consider how they can apply the guidance to protect themselves and to maintain the wider effectiveness of the SARs regime. 

New DAML guidance for insolvency practitioners

ICAEW and the National Crime Agency have worked together to produce some new guidance on Defence Against Money Laundering (DAML) requests. 

SARs reporting: emerging threats

In the rapidly changing landscape of economic crime, new risks are emerging all the time. In the second part of our interview with Martin Cox of the UK Financial Intelligence Unit (UKFIU), we talk about COVID-19, Fintech, cryptoassets and human trafficking. 

Reporter Booklet

Read the UKFIUs SARs Reporting Booklet that includes examples of how law enforcement agencies utilise SAR intelligence to initiate investigations and informing existing ones.

Join us: Client Due Diligence webinar

Join us for the third in our series of live AML webinars on 20 October 2021 at 11:00 to hear from members of ICAEW’s AML supervisory team, AML professionals and MLROs on how Client Due Diligence (CDD) operates in practice. You’ll learn about the key elements of CDD, what your obligations are and will have the opportunity to have your questions answered in our live Q&A session. 

The role of the MLRO: beyond compliance

Taking on the role of money laundering reporting officer can be daunting, and it isn’t always clear what’s required of you. We talk to ICAEW’s anti-money laundering supervisory team about the legislative background to the role, the importance of an open culture, and the unexpected skills you’ll need to do the job effectively. 

Watch again: SARs webinar recording

In case you missed it, you can now watch a recording of the second in our series of AML webinars on DAMLs and Tipping Off. 

Raise an AML concern

If you believe a firm supervised by ICAEW is breaching the Money Laundering Regulations 2017, you can raise your concern confidentially. 

Further links and resources