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Client due diligence on your client’s client
Archive
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..

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..

13 Oct
2015

10 new hot EBA releases this quarter

  • 13th October 2015
  • Aisha Dudhia

JWG analysis. The European Banking Authority (EBA) have been particularly busy this year, publishing over 30 key documents (5 consultations, 5 guidelines, 7 technical standards, 4 opinions and 11 reports and other notable publications) between June and August. Keeping up this pace, according to the EBA’s September newsletter, we can expect 25 deliverables covering 16..

18 Sep
2015

To LEI or not to LEI?

  • 18th September 2015
  • Mark Robinson

JWG analysis. Continuing our Legal Entity Identifier (LEI) series, from when the universal identification of financial entities was a mere idea on the horizon to its steady increase in prominence and complexity, we now mark a new date in the KYC calendar with the arrival of the consultation paper for level 2 relationship data for..

03 Jul
2015

AMLD IV: another brick in the wall

  • 3rd July 2015
  • David Miller

JWG analysis. Since 2008, regulators have been plugging the gaps revealed by the global financial crisis and have just put another brick in the financial services wall – the 4th Money Laundering Directive. Last month, the much anticipated ‘IV’ was published in the official journal and will become the law of the land in 2..

02 Jul
2015

What if your investment-based crowdfunding platform is operating outside the scope of MiFID?

  • 2nd July 2015
  • RegTechFS

JWG analysis. Today ESMA published a Q&A, aiming to clarify the status of investment-based crowdfunding platforms which are outside the scope of MiFID and, therefore, not automatically subject to rules designed to combat money laundering and terrorist financing under AMLD III. Investment-based crowdfunding platforms can have a different regulatory status.  Some are within the scope..

02 Apr
2015

KYC regulatory challenges: on deck and ready to go?

  • 2nd April 2015
  • RegTechFS

JWG analysis. Firms have plenty of planes in the air right now.  The regulatory pressure on firms to ‘get KYC right’ in the form of new financial crime regulation, such as FATCA or AMLD IV, and huge fines means they will need to juggle these changes amidst an ongoing regulatory implementation effort. How you need..

10 Mar
2015

Knowing the compliant customer in 2016

  • 10th March 2015
  • RegTechFS

JWG analysis. Regulations like FATCA, EMIR and Dodd-Frank have asked us to collect more information on our customers than ever before – but now it’s clear that was just the start of the story.  New regulation finds regulators even hungrier for information on the firm’s relationship with its customer, together with details of how information..