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On June 19, Delegated Regulation (EU) 2020/855 (the Delegated Regulation) was published in the Official Journal of the EU. The Delegated Regulation amends the list of high-risk third countries with strategic anti-money laundering (AML) and counter-terrorist financing (CTF) deficiencies produced under the Fourth Money Laundering Directive (MLD4).…
Continue Reading AML: Delegated Regulation on High-Risk Third Countries under MLD4 Published in the Official Journal of the EU

On May 28, the National Futures Association (NFA) submitted to the Commodity Futures Trading Commission (CFTC) proposed amendments to NFA Interpretive Notice 9045 (Interpretive Notice) regarding the anti-money laundering (AML) Programs that introducing brokers (IBs) (and futures commission merchants) are required to implement. …
Continue Reading NFA Proposes Amendments to Interpretive Notice Regarding AML Programs

On May 7, the European Commission (the Commission) adopted a new Delegated Regulation to amend the list of high-risk third countries with strategic anti-money laundering (AML) and counter-terrorist financing (CTF) deficiencies under the Fourth Money Laundering Directive (the Delegated Regulation).

The Delegated Regulation will:…
Continue Reading AML: European Commission Adopts a New Delegated Regulation in Relation to the Fourth Money Laundering Directive

On February 4, the UK’s Joint Money Laundering Steering Group (JMLSG) announced proposed amendments to its anti-money laundering (AML) and counter-terrorist financing (CTF) guidance (the Guidance). The JMLSG is a UK-focused group of trade bodies which produces AML and CTF guidance to assist the financial services industry.…
Continue Reading AML: JMLSG Proposes Amended Guidance

On January 23, HM Treasury (HMT) published its response (the Response) to the Consultation on the Transposition into UK law of the EU’s Fifth Money Laundering Directive (the Consultation). The Consultation closed in June 2019.

The Fifth Money Laundering Directive (MLD5) is primarily focused on expanding the EU’s anti-money laundering (AML) regime into new areas such as crypto-assets and art dealers. It became operational in the UK on January 10 (for more information, please see the January 10 edition of Corporate & Financial Weekly Digest).…
Continue Reading HMT Responds to MLD5 Consultation

On January 20, the Financial Conduct Authority (FCA) published a letter to the CEOs of UK-based alternative investment firms to outline the FCA’s view of the key risks of harm to the customers or markets in which such firms operate (the Letter). The FCA defines alternative investment firms as firms that predominately manage alternative investment vehicles (such as hedge funds or private equity vehicles), or manage alternative assets directly, or provide advice on such vehicles or assets.…
Continue Reading FCA Publishes Dear CEO Letter for UK Alternative Investment Firms

On January 10, the changes introduced by the European Union’s fifth Money Laundering Directive (MLD5) became operational. MLD5 came into force on July 9, 2018, but member states had until January 10 to transpose these changes into national law. MLD5 amends and builds on the fourth Money Laundering Directive (MLD4).  More information is available in the February 12, 2016 edition of Corporate & Financial Weekly Digest.
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Continue Reading Fifth Money Laundering Directive Becomes Operational

On October 16, the Financial Industry Regulatory Authority (FINRA) published its 2019 Report on Examination Findings and Observations (Report). Unlike previous years, the Report delineates between examination “findings” and examination “observations.” “Findings” describe violations of a rule or regulation, whereas “observations” refer to suggestions regarding how firms can improve controls and mitigate risk. The annual Report summarizes various findings and observations from recent examinations of its member firms on a range of topics, including the following:…
Continue Reading FINRA Issues 2019 Report on Examination Findings and Observations

On October 25, the Financial Conduct Authority (FCA) published a new webpage setting out important information for UK cryptoasset businesses in the context of anti-money laundering (AML) and counter terrorist financing (CFT).

As announced in July 2019, the FCA will be the AML/CFT regulator for certain cryptoasset activities starting January 10, 2020. However, the scope of ‘cryptoasset activities’ is still to be determined by Her Majesty’s Treasury (HMT), whose consultation on the matter closed on June 10.…
Continue Reading FCA Publishes Cryptoasset AML/CFT Webpage