On 20 December 2019, we received a festive treat: the publication of the Money Laundering and Terrorist Financing (Amendment) Regulations 2019 (the “Regulations”). The Regulations, which will come into force on 10 January 2020, implement the Fifth EU Money Laundering Directive (Directive (EU) 2018/843, “5MLD”)) in the UK, and follow a high level consultation in summer 2019.
The Regulations make some limited but important amendments to the existing Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (“MLR“). These include an expansion of the scope of the regulated sector, and changes to aspects of regulated firms’ customer due diligence and enhanced due diligence obligations (including, in particular, an important new requirement to make reports to Companies House in relation to discrepancies between information collected during customer due diligence and information on the Persons with Significant Control register). In this briefing we review the changes and new obligations.