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
- Wire transfers – material moved from Part II and extended
- Equivalence (jurisdictions and markets) – presently on the JMLSG website
- Directions under the Counter-Terrorism Act 2008, Schedule 7 – material moved from Part I
- New material on Compliance with the UK financial sanctions regime, and on Proliferation financing
By specialist sector
Sector 1 Transparency in electronic payments
- Re-name the section, to reflect the wider coverage of the former wire transfer material
- Extend the scope to include cover payments
- Other amendments to remove reference to future events that have now taken place
Chapter 2 Equivalent jurisdictions
- Move from the website
- Amend to reflect FATF and HM Treasury pronouncements since February 2009
- Incorporate other updating amendments
Chapter 3 Equivalent markets
- Move from the website with no amendment
Chapter 4 Compliance with the UK financial sanctions regime
- New guidance on what the UK regime comprises
- Specific guidance on possible approaches and procedures (including risk assessment), screening and reporting
Chapter 5 Directions under the Counter-Terrorism Act 2008
- Move from Part I
- Amend to reflect the experience of the issuance of directions by HM Treasury
Chapter 6 Proliferation financing
- New (preliminary) guidance on approaching the assessment of whether customers are likely to be involved in proliferation financing
- Guidance on how risk assessment procedures might include PF considerations
May 2010