AML News - January 2025

International

The Financial Action Task Force (FATF)

• Published reports on progress in strengthening measures to tackle ML/TF for Belize, Slovak Republic, Bolivia, Estonia, Djibouti, Samoa, Iraq, Tajikistan, and Myanmar.
• Issued an updated version of the Consolidated Assessment Ratings. The Ratings provide an up-to-date overview of the ratings on both effectiveness and technical compliance for all countries assessed against the 2012 FATF Recommendations and using the 2013 Assessment Methodology.

United Kingdom

Financial Conduct Authority (FCA)

• Published an updated analysis on ML through the markets (MLTM) risk. The FCA has found that wholesale brokers need to enhance their systems, controls, risk awareness, and training to guard against money laundering.
• Issued an article on the use of the National Fraud Database (NFD) and money mule account detection tools. This article outlines findings from a review of payment services and account providers’ use of the National Fraud Database (NFD) and a money mule account detection tool to tackle risks associated with money muling activities.

National Crime Agency 

• Published the Jan 2025 SARS Reporter Booklet. This booklet contains a summary of feedback from law enforcement agencies (LEAs) on their use of SARs.

European Union

European Council 

• Announced a renewal of the EU Terrorist List and related humanitarian exceptions.

Europol

• Published the Practical Guide for Operational Cooperation between Investigative Authorities and Financial Institutions. This guide provides an overview of why and how to ensure successful operational cooperation between financial institutions and investigative authorities to combat financial crime.

Germany 

BaFin

• Published Interpretation and Application Guidance for insurance undertakings and credit institutions. The guidance supplements and specifies in greater detail the general interpretation and application guidance in relation to the ML Act.

Jersey

Jersey Financial Services

• Released information on the 2024 AML/CFT/CPF and supervisory risk data collection exercise. All supervised businesses must provide their 2024 data between 13 Jan and 11 Apr 2025. This data informs the approach for risk-based supervision and the financial crime examination process. It will also be used in aggregated form to refresh the JFSC’s risk model and National Risk Assessments.

Philippines

Anti-Money Laundering Council (AMLC)

• Published Guidelines on Transaction Reporting and Compliance Submissions (GoTRACS). Updates in the Guidelines include the reinstatement of some low-risk transactions as reportable CTRs, the addition of low-risk transactions, and the introduction of new STR file types. 

Singapore 

Monetary Authority of Singapore (MAS)

• Released a Compliance Toolkit for Approvals, Notifications and Other Regulatory Submissions to MAS for Wholesale Banks and Full Banks and Merchant Banks. This Compliance Toolkit aims to guide and facilitate understanding and compliance with the various MAS approval, notification, and reporting requirements and timelines.
• Issued Notice SFA02-N05 and associated guidelines to Approved Exchanges and Recognised Market Operators on the Prevention of AML/CFT. The requirements for approved exchanges and recognised market operators can be found in this notice, which, amongst other requirements, includes risk assessment and risk mitigation as well as customer due diligence.

British Virgin Islands

Financial Investigation Agency

• Issued guidance on effective ongoing monitoring. Effective monitoring involves an ongoing review of clients and business relationships as well as the monitoring of transactions, including one-off transactions, in order to identify for the purpose of reassessing the client’s risk rating, transactions that may present elevated risk, unusual or suspicious transactions, and transactions that are in breach of targeted financial sanctions.
• Launched a public consultation on the draft policy on access to the Register of Beneficial Ownership. The consultation relates to new statutory requirements mandating that all beneficial ownership information be filed with the Registry of Corporate Affairs Division of the BVI Financial Services Commission (the Commission) via the VIRRGIN platform.

• Announced the Publication of its 2024 Compliance Inspection Findings. The Report has collated the overall findings and positive practices identified to allow for consideration and potential implementation of such practices by industry participants. The report also notes a number of areas for improvement and outlines possible recommendations to improve compliance with the AML/CFT/CPF requirements in the Territory.

• Published FAQs On Beneficial Ownership Implementation. The FAQs seek to address commonly raised questions in relation to filing documents in connection with legal arrangements, trust, nominee shareholders, and beneficial owners while also covering issues such as fees, troubleshooting, and exemptions.

Other Jurisdictions

No major updates this month.