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HM Treasury has now formally approved the outstanding JMLSG Guidance

01/05/2025

HM Treasury has now formally approved the outstanding JMLSG Guidance – the Highlights include

  1. JMLSG, Part I, Para 5.3.89 – Update to electronic/digital identification – https://www.jmlsg.org.uk/wp-content/uploads/2023/07/JMLSG_Part-I-Para-5.3.89_Board-approved_July-2023.pdf
    1. Enhancing the UK’s approach to non-face-to-face business to update it with current digital technology –
    2. With appropriate controls, non-face-to-face may not pose a higher risk.
  2. JMLSG, Part I, Paras 5.3.129A-C (discrepancy reporting) – https://www.jmlsg.org.uk/wp-content/uploads/2023/10/JMLSG-Guidance_Part-I-Chapter-5_Para-5.3.129A-C_Board-approved.pdf
    1. Covering a proportionate approach to UK material discrepancy reporting of Beneficial Ownership information.
    2. Discrepancies arising from administrative or clerical errors, or due to chronological factors affecting timely updates of the registers, are unlikely to constitute concealment and therefore are unlikely to be reportable.
  3. JMLSG, Part II, Sector 18 – Wholesale Markets – https://www.jmlsg.org.uk/wp-content/uploads/2024/09/Part-II-Sector-18_Sept-2024_Board-approved.pdf
    1. Wholesale Subscription Finance in Private Capital Funds (NEW) - Addressing a gap in Guidance for the UK financial services industry by supporting the Banking and NBFI eco-system.
    2. This is the first Guidance of its kind globally that sets out who the firm’s customers are, who is not, and the application of due diligence measures in these multi-party arrangements on a risk-based approach.
  4. JMLSG, Part II, Sector 18 - Wholesale Markets – https://www.jmlsg.org.uk/wp-content/uploads/2024/09/Part-II-Sector-18_Sept-2024_Board-approved.pdf
    1. Persons acting on Behalf of / Authorised Personnel acting on behalf of the Customer - Outlining a proportionate approach to fulfilling this MLR obligation within the regulated sector.

These Guidance updates constitute a proportionate and risk-based approach to focal elements under the UK MLRs, supporting financial institutions in deploying resources in a targeted and effective manner.

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As well as owning and publishing Comsure's copyrighted works, Comsure wishes to use the copyright-protected works of others. To do so, Comsure is applying for exemptions in the UK copyright law. There are certain very specific situations where Comsure is permitted to do so without seeking permission from the owner. These exemptions are in the copyright sections of the Copyright, Designs and Patents Act 1988 (as amended)[www.gov.UK/government/publications/copyright-acts-and-related-laws]. Many situations allow for Comsure to apply for exemptions. These include 1] Non-commercial research and private study, 2] Criticism, review and reporting of current events, 3] the copying of works in any medium as long as the use is to illustrate a point. 4] no posting is for commercial purposes [payment]. (for a full list of exemptions, please read here www.gov.uk/guidance/exceptions-to-copyright]. Concerning the exceptions, Comsure will acknowledge the work of the source author by providing a link to the source material. Comsure claims no ownership of non-Comsure content. The non-Comsure articles posted on the Comsure website are deemed important, relevant, and newsworthy to a Comsure audience (e.g. regulated financial services and professional firms [DNFSBs]). Comsure does not wish to take any credit for the publication, and the publication can be read in full in its original form if you click the articles link that always accompanies the news item. Also, Comsure does not seek any payment for highlighting these important articles. If you want any article removed, Comsure will automatically do so on a reasonable request if you email info@comsuregroup.com.  

news disclaimer -

As well as owning and publishing Comsure's copyrighted works, Comsure wishes to use the copyright-protected works of others. To do so, Comsure is applying for exemptions in the UK copyright law. There are certain very specific situations where Comsure is permitted to do so without seeking permission from the owner. These exemptions are in the copyright sections of the Copyright, Designs and Patents Act 1988 (as amended)[www.gov.UK/government/publications/copyright-acts-and-related-laws]. Many situations allow for Comsure to apply for exemptions. These include 1] Non-commercial research and private study, 2] Criticism, review and reporting of current events, 3] the copying of works in any medium as long as the use is to illustrate a point. 4] no posting is for commercial purposes [payment]. (for a full list of exemptions, please read here www.gov.uk/guidance/exceptions-to-copyright]. Concerning the exceptions, Comsure will acknowledge the work of the source author by providing a link to the source material. Comsure claims no ownership of non-Comsure content. The non-Comsure articles posted on the Comsure website are deemed important, relevant, and newsworthy to a Comsure audience (e.g. regulated financial services and professional firms [DNFSBs]). Comsure does not wish to take any credit for the publication, and the publication can be read in full in its original form if you click the articles link that always accompanies the news item. Also, Comsure does not seek any payment for highlighting these important articles. If you want any article removed, Comsure will automatically do so on a reasonable request if you email info@comsuregroup.com.