The global anti-money laundering standard-setter has identified 15 countries it says have failed to take adequate steps to combat money laundering and terrorist financing. At the top of the Financial Action Task Force’s list are     Iran and     North Korea, both of which have pushed forward with nuclear programs despite U.S. objections and sanctions. […]

10 years seems to the best practice limit in the industry although I accept the Money Laundering rules require that for a relevant person must make and retain orderly records of CDD information for at least 5 (five years) from the end of the relationship with the customer (or the completion of the transaction, for […]

A key focus for many listed investment funds at this time of year is finalising their annual report and annual general meeting. This briefing aims to pull together the key developments over the last twelve months which may impact on the 2013 annual report and AGM.   There are no compulsory changes this year in […]

 Rapid change seems to be the order of the day, as the speed and complexity of business continue to increase. Technological advances such as cloud computing, mobile devices and social media continue to take hold. Regulatory demands continue to expand. Workforce dynamics continue to evolve. These and numerous other trends spawn new risks, altering risk […]

Client Confidentiality and AML Compliance In Jersey – Jersey has never had, contrary to the belief held by some, banking secrecy enshrined in statute. It does have a statutory regime of data protection and client confidentiality is, of course, an important principle and fundamental to the relationship between banker and client. The principle was recognised […]

Sanitised case 3 A Jersey company owned a private luxury yacht which had been acquired for US$20m. About 30% of the acquisition was financed from bank loans, the remaining 70% was believed to have been privately funded from the two beneficial owners of the company. A recent letter from a Middle Eastern construction company identified […]

On 5 February 2013, the European Commission published draft versions of two legislative proposals regarding money laundering and funds transfers: (1) a directive on the prevention of the use of the financial system for money laundering and terrorist financing (commonly referred to as “MLD4”), and (2) a regulation on the information to accompany transfers of […]

The Financial Services Authority (FSA) is currently undertaking one of four planned thematic reviews into firms’ compliance with new rules following the Retail Distribution Review (RDR). Here are the 39 questions the regulator is asking its sample of 50 firms – and which you should be thinking about too… 1. Are services offered by your […]