Published: 25th April 2016

Of relevance to:

All firms and in particular MLROs.


Anti-Money Laundering Action Plan

The Home Office and HM Treasury have published a joint “Action Plan for anti-money laundering and counter-terrorist finance”.

The purpose of the Action Plan, so we are told, is to send out a clear message that the Government is determined to protect the security and prosperity of its citizens and the integrity of the UK’s financial system.

The document is concerned with three priorities:

  • The need to create ‘aggressive new legal powers’ to enable the relentless disruption of criminals and terrorists.
  •  To reform the supervisory regime to ensure that a risk-based, and proportionate, approach is pursued so that efforts are focussed on the highest risks “without troubling low risk clients with unnecessary red-tape”.
  • To increase the UK’s international reach by working with the likes of the G20 and the Financial Action Task Force to take action overseas.
    Current guidance that firms can fall back on includes that provided by the FCA (Financial Crime Guide – FC) and that provided (in three parts) by the Joint Money Laundering Steering Group (“JMLSG”). Interestingly the document specifically mentions feedback received that the FCA Financial Crime Guide is unclear and inconsistent with the guidance produced by the JMLSG (page 50). One of the questions posed in the Action Plan is whether the guidance should be merged or, alternatively, should one of them be discontinued?

A summary of actions can be found on pages 5 and 6.

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