Here’s your chance to vent your frustrations on AML laws

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The UK Government’s “Cutting Red Tape” initiative includes a review of the impact on business of the current anti-money laundering & terrorist finance regime. This review allows stakeholders to submit their comments on their compliance challenges with UK AML laws.

Details of the review and how you can respond are set out below.

Purpose of the AML law review

As stated on the initiative’s website:

This Review is seeking evidence of the impact on business of the current anti-money laundering and terrorist finance regime, and specifically the role of supervisors in that regime. It seeks to identify any aspects of regulatory activity that could be made more efficient – both for those that operate the regime and are subject to it and for enforcing authorities

Deadline for responses – Friday 23 October 2015

Submissions can be made here.

Thoughts on the UK AML laws review

It is worth bearing in mind that this review will not impact the UK’s obligations to comply with its EU AML obligations, including the transposition of the 4MLD.

The review is aimed at understanding inefficiencies with compliance with AML/CTF obligations. Even though it is not aimed at reviewing the substantive law, it is still welcomed as a means of examining the practical issues of complying with the AML laws regime. In particular, aspects on how to comply with KYC and using innovative technology is likely to be a focus of many in the AML regulated sector.

For more information on the types of matters subject to the review, its website is calling for evidence of the impact on business for matters including those such as:

The effectiveness and proportionality of the supervisors’ approach to supervision and enforcement, and how could this be improved


How and where businesses access information about their compliance, and how effective and proportionate is AML/CTF guidance (for example FCA and JMLSG guidance).


Evidence of over-implementation (given that due diligence on customers should be proportionate to the risks posed), and on the range of tools to address this and how are they used


Whether self-regulation supports an effective and proportionate AML/CTF regime


Good practice examples of activity or approaches taken by supervisors to support business compliance, which could be replicated elsewhere


Evidence of the supervisory regimes in other countries that we can learn from, or that impacts on businesses in the UK


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