The EU’s 5th Money Laundering Directive came into force on 10 January 2020, amending the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017.
Firms must be compliant with the new regulations from 10 January 2020.
The Solicitors Regulation Authority has said they’ll take the limited time that firms have had to prepare into account in their enforcement work.
The Legal Sector Affinity Group (LSAG), which includes the Law Society and all the legal sector supervisors named in the anti-money laundering regulations, has published a summary of changes to the regulations to help firms comply with the new requirements. This includes:
- a duty to collect proof of registration for entities (for example trusts and companies)
- a duty to inform the registry of any discrepancies in their information
- changes to client due diligence and enhanced due diligence
LSAG is currently redrafting the full guidance on the regulations. This will require the approval of HM Treasury and will be published in the coming months. In the meantime, you should still consult the full guidance on most questions.