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RegRoundup 4 April: the pursuit of clarity
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04 Apr
2016
financial services regulation, fs regulation summary

RegRoundup 4 April: the pursuit of clarity

In the post-Easter week, regulators were busy shining a spotlight on remuneration practices in the industry.  We saw the EBA releasing a report looking at the high earners in EU banks and ESMA focusing on sound remuneration policies under the UCITS Directive and AIFMD. The FSB also met in Tokyo to discuss their priorities for..

01 Apr
2016

The UK puts one foot forward in the battle for more transparency on beneficial ownership

  • 1st April 2016
  • David Miller

FinCEN’s proposed rules on beneficial ownership due diligence, the incoming 4th Money Laundering Directive (AMLD IV) and now the UK’s Register of People with Significant Control (PSC) Regulation all push for more transparency in beneficial ownership or significant control of companies. The aim is to reduce acts of money laundering and tax evasion and to..

04 Mar
2016

Financial crime and counter terrorist financing updates

  • 4th March 2016
  • David Miller

The attacks in Paris and the continued threats posed by the Islamic State of Iraq and the Levant (ISIL) have once again seen fresh emphasis placed by financial regulators around the world on countering terrorist financing and money laundering. The Financial Action Task Force (FATF), a Paris based intergovernmental body that sets standards and promotes..

02 Mar
2016

The RegTech marketplace: in depth analysis (Part 1 of 3)

An EY report released this week in conjunction with the UK Treasury, declared the UK to be the highest ranking FinTech sector in the world with a market size of £6.6 billion.  The authors predominantly attributed this to the UK’s accommodative regulatory regime for startups and the associated disruptive technologies they bring to market. We..

21 Jan
2016

FATF updates – renewing effort to tackle terrorism

  • 21st January 2016
  • David Miller

FATF updates – renewing effort to tackle terrorism A special three-session meeting to discuss tackling terrorist financing was organised by the Financial Action Task Force in reaction to the atrocities that have taken place in the last few months.  Whilst the agenda focused on broader ways to tackle terrorist financing, the Islamic State of Iraq..

14 Jan
2016
client due diligence, money laundering directive due diligence, fatf de-risking clients

Client due diligence on your client’s client

  • 14th January 2016
  • David Miller

The UK, EU and the Financial Action Task force have promoted banks to adopt and implement a measured approach to de-risking clients that pose money laundering and financial crime risks.  The central message has been for financial institutions to manage money laundering risks and to cease relationships with clients as a last resort. But, the..

07 Jan
2016
Chief Compliance Officer, CCO, nysdfs aml regulation, senior managers regime, SMR, smr implementation, senior managers regime implementation

Another step towards increasing individual accountability

There will no doubt be many concerned faces amongst senior management this year as the new rules for the Senior Managers and Certification Regime (SMR) come into force over the next 12 months.  The first implementation date will be in February 2016 when firms will have to submit documents for grandfathering, then commencement of the..

14 Dec
2015

AML risk-based approach – logical, but is it straight forward?

  • 14th December 2015
  • David Miller

AMLD IV has placed emphasis on a risk-based approach to counter financial crime and terrorist financing. Few would argue against this approach. It is not only logical, but also the most practical way forward. The approach appears to be fairly straightforward, consisting of identification, assessment and management risk. However, recent news, analysis and conversation with..

29 Oct
2015

Assessing risk – ESMA draft guidelines on AML

  • 29th October 2015
  • David Miller

JWG analysis. Over the last 10 months, JWG’s CDMG has covered – in depth – the incoming Anti-Money Laundering Directive IV (AMLD IV). AMLD IV focuses on the risk profiles of clients and monitoring or reporting them accordingly. On 21 October, ESMA published a Joint Consultation Paper on simplified and enhanced due diligence, detailing the..

14 Oct
2015

Managing the complexities of client classification: the MiFID II push for LEIs

  • 14th October 2015
  • Mark Robinson

JWG analysis. As financial regulations keep piling up in the post-crisis world, it becomes increasingly difficult to recognise the similarities and differences between them.  The interdependencies on the Know Your Customer (KYC) front are present, but somewhat tangled.  Here we provide an overview of the current and upcoming client classification requirements under prominent regulations, and..