Regulatory update
Amendment to the Money Laundering Regulations
A new Statutory Instrument came into force on 10 January 2024. It puts into legislation that a domestic politically exposed person (PEP) has a lower starting point for risk than a foreign PEP and, if no enhanced risk factors are present, the extent of customer due diligence for a domestic PEP should be lower than a foreign PEP.Revised CCAB Guidance for the Accounting Sector
The CCAB’s AML Guidance for the Accounting Sector was revised in June 2023. The amendments related to proliferation financing and ‘ongoing’ discrepancy reporting requirements.
Update to Schedule 3ZA of the Money Laundering Regulations
The list of high-risk third countries has been updated in line with Financial Action Task Force statements in October 2023.
This update means:
- Bulgaria, Cameroon, Croatia, Nigeria, South Africa and Vietnam have been added to the UK’s high-risk third countries list.
- Albania, Cayman Islands, Jordan and Panama have been removed.
Economic Crime and Corporate Transparency Act received Royal Assent
Read about the new measures to verify information held on the company register and the new offence of failure to prevent fraud.
Suspicious Activity Reporting
New SARs Portal
Users are no longer able to register for, or add a new user, to the National Crime Agency’s old suspicious activity reporting portal.
If you need to submit a SAR, you should no longer use the old portal which will shortly be decommissioned. Instead you must register for the new SAR Reporting Portal, which should then be used as your firm’s sole reporting route. Additional registration and SAR submission guidance is available via the NCA’s website.
UK Financial Intelligence Unit Resources
The UKFIU has published new resources to support firms in improving the quality of the information they submit via suspicious activity reports:
SARs webinar: insights from the National Crime Agency
Guidance for both money laundering reporting officers and individuals participating in the submission of suspicious activity reports to the National Crime Agency. The webinar will take place on 13 March.
Sanctions
New red alert
The National Crime Agency issued a red alert warning businesses that Russia is attempting to circumvent sanctions to purchase restricted goods and services, through intermediary countries.
New entries to the consolidated sanctions list
The UK Government continues to add new entries to the Russia and Belarus financial sanctions regime. Make sure you are up to date with your sanctions checking.
Reminders
Have your say on how you use Companies House information
The Department of Business & Trade and Companies House are carrying out a survey to understand how the corporate transparency information made available by Companies House is used by businesses that are required to comply with the UK Money Laundering Regulations. The results will be used to assess the effectiveness of planned reforms to Companies House that will improve the reliability of corporate transparency information with the ultimate aim of tackling crime.
Spotting Companies House scams
What to do if you think you've spotted a scam pretending to be from Companies House. The article includes examples of scam emails, letters and telephone calls.
Avoid losing access to your agent account
Failing to respond to an innocuous looking letter from HMRC can end up with your agent account being blocked.