| Link(s): | The Money Laundering and Terrorist Financing (Amendment) Regulations 2023 (legislation.gov.uk) The Money Laundering and Terrorist Financing (Amendment) Regulations 2023 (legislation.gov.uk) |
Context
An amendment to the Money Laundering Regulations 2017 (the Money Laundering and Terrorist Financing (Amendment) Regulations 2023 (SI 2023/1371)) has been published, along with an explanatory memorandum. The amendment (which is already established in Guidance) clarifies the explicit differences between domestic and non-domestic politically exposed persons (PEPs).
Key points to note and next actions
The amendment clarifies in law that, for the purposes of applying the MLRs, domestic PEPs pose a lower risk of money laundering and terrorist financing than non-domestic PEPs, and that the extent of enhanced due diligence measures applied to those customers by firms regulated under the MLRs should be less, unless other risk factors unrelated to their position as a domestic PEP apply.
The amendment states, when referring to a domestic PEP, that “the starting point for the assessment is that the customer or potential customer presents a lower level of risk than a non-domestic PEP”.