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30 April 2015

Money Laundering & Terrorist Financing

The Financial Conduct Authority has now published their revisions to the Firms Guidance on Financial Crime that came into effect on 27th April 2015. The regulator amended various sections including Chapter 2 on Systems & Controls (affecting Management Information and Risk Assessments) and Chapter 3 on Money Laundering and Terrorist Financing. In particular, their revisions to Chapter 3 focused upon source of wealth and source of funds, as summarised below, in addition to Enhanced Due Diligence (EDD) and the handling of higher-risk situations.

Summary of Chapter 3 Revisions:

Source of wealth and source of funds

Determining the source of funds and the source of wealth can help firms establish if the level and type of business and transactions are consistent with the firm’s knowledge on the customer and is helpful for due diligence and ongoing monitoring. This also must be determined where the customer is a Politically Exposed Person (PEP).

The Joint Money Laundering Steering Group’s (JMLSG) guidance allows that in circumstances where the risk of money laundering and/or terrorist financing is very low, (and subject to certain conditions), firms may assume that payments drawn on an account in the customer’s name with a regulated credit institution (within the UK, EU or equivalent) is sufficient to satisfy standard Client Due Diligence (CDD) requirements.

Often this is referred to as ‘Source of Funds Evidence’, however it should be clear that this is wholly separate to ‘Source of Funds’ for the purposes of Regulation 8 and Regulation 14 of the Money Laundering Regulations 2007 and with regards to the FCA’s Guidance on Financial Crime, although it should be said that nothing in the FCA’s Guide prevents the use of Source of Funds Evidence in appropriate circumstances.

Further Reading:



Money Laundering & Terrorist Financing: Source of Funds & Source of Wealth