JMLSG Guidance Part III

JMLSG today publishes Part III of its Guidance for the UK financial sector.  As explained when the consultation version was published, Part III includes certain existing material that for various reasons did not sit comfortably within Parts I or II, and some additional, new material. 

No substantive changes have been made to the consultation text as a result of comments received, although there has been some re-ordering of the text to improve clarity, and to reduce some elements of duplication.

JMLSG is discussing with HM Treasury the extent to which Ministerial approval might be given to different sections of the Part III text.  In addition, JMLSG is aware that some of the legal references in its Guidance, in particular the new text on compliance with the UK financial sanctions regime, will require amendment to reflect the eventual passing of the Terrorist Asset Freezing etc Bill into law, which is expected before the end of 2010.  JMLSG considered holding back publication of the guidance in this area until the Bill was passed, but concluded that, as it will likely only be legal references that change, firms would wish to see the final text at the earliest opportunity.