E2: Money Laundering Regs 2007

Annotations:

• - took effect Dec 07 - implement req's of 3MLD - interpretation of regs by Joint Money Laundering Steering Group (Chaired by Bank of England & including leading Trade Assoc.) - risk-based approach assessed by firms/practioners to extent of complaince work they need to carry out

1. Businesses covered
   1. credit/financial institutions

      Annotations:

      • - life ass. cos - fin advisers - savings & invstmnt firms - deposit takers - bureaux de change
   2. auditors/accountants/tax advisers/insolvency practioners
   3. Independent legal professionals
   4. trust/company service providers
   5. estate agents
   6. casinos
   7. high value dealers (goods value greater than 15k euros
   8. leasing companies/commercial finance providers/safe custody services
2. policies & procedures
   1. appoint MLRO

      Annotations:

      • - based in UK - level of authority & independence within firm - access to sufficient resources & info to carry out responsiblities
   2. exist to minimise risk
      1. covers due diligence
      2. reporting
      3. record keeping
      4. internal control
      5. risk assessment
      6. monitoring of complaince
3. Customer due diligence
   1. verify ID of customer & beneficial owner
   2. obtain info on purpose/nature of business relationship
   3. req'd?
      1. reg. firm establishes bus relationship
      2. carries out occasional transaction
      3. suspects money laundering/terrorist financing
      4. doubts about integrity of customer info
   4. not required?
      1. life policy annual premium <e1k or sp < e2.5k
      2. pension sv cannot be used as collateral for loan
      3. pension scheme members cannot assign right