AML Round-up: Forthcoming amendments to the MLRs and HMT’s review of the UK’s AML/CFT regulatory and supervisory regimes

In case you missed it while grappling with new sanctions in recent weeks, at the end of June 2022, HM Treasury (HMT) published the outcome of last year's consultation on forthcoming amendments to the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLRs) (the Consultation). These include a new requirement to assess and mitigate the risk of proliferation financing, in addition to amendments to the discrepancy reporting regime, and scope of the regulated sector. Some of the changes consulted upon will come into force shortly, on 1 September 2022. Read more

Russian sanctions evasion – key indicators for regulated firms

Our previous blogpost mentioned the recent red alert on sanctions evasion typologies issued by various law enforcement and financial sector partners. In this post we look at this update in more detail to identify potential indicators of sanctions evasion, and the steps that the alert indicates that financial sector and other anti-money laundering ("AML") regulated firms should be taking in this regard. Read more

Sanctions tracker – new UK trade sanctions

This briefing summarises the new Russia sanctions measures introduced by the UK on 23 June 2022 and provides a round-up of other key UK and EU developments since our last sanctions tracker post. Read more

Proposed amendments to MLRs – New change in control regime for cryptoasset businesses

At the moment, the FCA's only powers over crypto businesses which do not carry on investment, payment services, e-money or other UK regulated business come from its role as their anti-money laundering and counter-terrorist financing supervisor. This will change in due course in respect of stablecoin businesses (with HMT consulting on bringing these into scope) and in respect of financial promotions of certain cryptoassets (both HMT and FCA are consulting on this). Read more

Strict liability test for sanctions breaches come into force

Changes to the UK's financial sanctions regime, introduced by the Economic Crime (Transparency and Enforcement) Act 2022 (the "Act"), came into force today (15 June 2022) and, with them, the power for the Office of Financial Sanctions Implementation ("OFSI") to impose civil monetary penalties in respect of financial sanctions breaches on a strict liability basis (i.e. irrespective of any knowledge or suspicion). Read more