Context
Developments in Afghanistan have highlighted the continuing need for robust systems and controls that respond to changing risks.
Firms should be aware of the possible impact these events may have on patterns of financial activity when they assess risks related to particular customers and flows of funds. The FCA expects firms to establish and maintain systems and controls to counter the risk they might be used to further financial crime. Firms must also comply with their legal obligations under the Proceeds of Crime Act 2002 and the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (‘MLRs’ as amended).
Key points to note
Firms should consider the impact of these developments on their anti-money laundering policies and procedures in a risk-based manner and take the necessary steps to ensure they continue to meet their legal and regulatory anti-money laundering and reporting obligations. Firms should:
- ensure that they appropriately monitor and assess transactions to Afghanistan to mitigate the risks of their firm being exploited to launder money or finance terrorism;
- continue to ensure that suspicious activity is reported to the UK Financial Intelligence Unit (UKFIU) at the National Crime Agency (NCA) and that they meet their obligations under Money Laundering Regulations and terrorist financing legislation.
See the item below from HM Government on Afghanistan Sanctions.
Next actions
None – for information and awareness