Proposed Amendments to JMLSG Guidance (1 July 2013)

Over the past few months, the JMLSG Board has carried out a review of its Money Laundering Guidance for the Financial Sector, looking at:

    • areas of omission
    • provisions of the Guidance that are difficult to implement or effect
    • provisions of the guidance that no longer reflect current practice

Member trade associations were invited to make their comments under each aspect; in general, they only had a small number of amendments to suggest.  The comments received were considered by the Editorial Panel and by the Board.

The Board decided that it would not be appropriate to anticipate, at this time, any amendments to the Guidance that would be needed when the EC Fourth Money Laundering directive is adopted and implemented. Nevertheless, some contextual material from the new FATF documentation relating to the risk-based approach has been included in a proposed revision of Chapter 4.

References to the Financial Services Authority, or FSA, throughout the Guidance have been amended to refer to the Financial Conduct Authority or FCA (unless the references are to past FSA actions).  Similarly, references to HM Treasury’s Asset Freezing Unit have been amended to refer to Financial Sanctions.

The Board today publishes revised text of the relevant material in each Part, showing the amendments proposed.  The amendments proposed are summarised on the attached schedule.

The Consultation text is available in marked-up format:

Part I
Part II
Part III

JMLSG welcomes comment on the proposed amendments to its Money Laundering Guidance.  Comments may be made in hard copy or electronic form, and should be sent to:

David Swanney
Joint Money Laundering Steering Group
Pinners Hall
105/108 Old Broad Street

Comments should be received by 16 September 2013



Proposed amendment



Chapter 1

In paragraphs 1.5 – 1.10, the emphasis in references to international pressures has been changed to reflect stronger international expectations, and reference to the revised FATF Standards published in February 2012 is brought in. 

Paragraph 1.7 also refers to the draft EU Fourth Money Laundering Directive, published in February 2013, which proposes implementation of these revised Standards across the EU in due course.


Paragraph 1.19 (as does 1.35) makes reference to the need to be aware of supervisory expectations flowing from their thematic reviews.

Chapter 4

This chapter has been extensively amended and re-ordered, to update some of the text and to bring in contextual material from the revised FATF Recommendation 1 and related Interpretive Note.

Chapter 5

Paragraphs 5.3.135 and 5.3.164 have been amended to refer to the position when no one owns or controls 25% of an entity’s shares.


Paragraph 5.3.216 has been amended to clarify the position on obtaining confirmation letters from HMRC or the Pension Regulator.


Paragraph 5.3.239 has been amended to remove the reference to using GRO registration as evidence of identity.


Paragraph 5.5.6 has been amended to augment references to verifying the source of wealth or income

Chapter 6

In paragraph 6.9, references to the Limited Intelligence Value report have been deleted.


A few additional, clarificatory words have been added to the end of paragraph 6.72.



Sector 1

The incorrect reference to the ML Regulations has been corrected.

Sector 7

In paragraph 7.54 additional reference is made to customers determined as posing increased risk.

Sector 8

Paragraph 8.20 has been amended to include the possibility of the transfer of an account, as well as a payment, satisfying the standard identification requirement.



Equivalent jurisdictions

On page 10 of the 2013 Review Version, the reference to specific FATF Recommendations has been indicated as being to the old Recommendation numbers.

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