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Changes in money laundering requirements on the horizon
05 April 2013

Following the announcements of penalties on some major banks at the tail end of 2012 the European Commission has now published its re-working of the Money Laundering Directive to ensure it aligns with the Financial Action Task Force recommendations.  The proposal, which came out mid-February, will result in changes to our Money Laundering Regulations 2007 which implement the existing directive (3AMLD).  These revised regulations will inevitably require the financial crime teams of all authorised firms to consider the implications and update their procedures.   3AMLD applies to businesses in the financial sector, to lawyers, notaries, accountants, real estate agents, casinos and to company service providers.  It also applies to providers of goods when cash payments in excess of €15,000 (approx. £13,000) are made.


Those who are subject to the Directive need to ensure they: 

  • conduct appropriate levels of customer due diligence (CDD), by verifying the identity of their customers, and of any beneficial owners of their customers, and monitoring their relationships with the customers
  • report any suspicions of money laundering or terrorist financing to the relevant public authority
  • take appropriate internal supporting measures, for example ensuring the proper training of personnel and have in place suitable policies and procedures to support their anti-money laundering obligations.



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