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Comsure operates in:the UK, Jersey, Guernsey

Proposed Part III to JMLSG Guidance

The Board indicated in its note of 6 August 2009 that it was contemplating an additional Part III, which would include certain existing material that for various reasons did not sit comfortably within Parts I or II, and some additional, new material. Unlike Parts I and II, JMLSG does not anticipate that the Part III Guidance (apart from the guidance on CTA Sch 7) will be formally approved by a Treasury Minister.

Cover note to publiction of Part III (PDF) http://www.jmlsg.org.uk/content/1/c6/01/76/95/Cover_note_to_publication_of_Part_III.pdf

Part III Consultative (PDF) http://www.jmlsg.org.uk/content/1/c6/01/76/96/Part_III_text_CLEAN_May_2010.pdf

SUMMARY OF PROPOSED CONTENT OF PART III

General

  1. Wire transfers – material moved from Part II and extended
  2. Equivalence (jurisdictions and markets) – presently on the JMLSG website
  3. Directions under the Counter-Terrorism Act 2008, Schedule 7 – material moved from Part I
  4. New material on Compliance with the UK financial sanctions regime, and on Proliferation financing

By specialist sector

Sector 1 Transparency in electronic payments

  1. Re-name the section, to reflect the wider coverage of the former wire transfer material
  2. Extend the scope to include cover payments
  3. Other amendments to remove reference to future events that have now taken place

Chapter 2 Equivalent jurisdictions

  1. Move from the website
  2. Amend to reflect FATF and HM Treasury pronouncements since February 2009
  3. Incorporate other updating amendments

Chapter 3 Equivalent markets

  1. Move from the website with no amendment

Chapter 4 Compliance with the UK financial sanctions regime

  1. New guidance on what the UK regime comprises
  2. Specific guidance on possible approaches and procedures (including risk assessment), screening and reporting

Chapter 5 Directions under the Counter-Terrorism Act 2008

  1. Move from Part I
  2. Amend to reflect the experience of the issuance of directions by HM Treasury

Chapter 6 Proliferation financing

  1. New (preliminary) guidance on approaching the assessment of whether customers are likely to be involved in proliferation financing
  2. Guidance on how risk assessment procedures might include PF considerations

May 2010


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