HM Treasury has published a consultation on improving the effectiveness of the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (the ‘MLRs’), which place requirements onto a range of businesses to identify and prevent money laundering and terrorist financing.
HM Treasury committed to consulting on changes to the MLRs as part of a wider programme of work aimed at reducing money laundering, which was set out in the Economic Crime Plan 2023-26. This consultation principally covers issues with the MLRs already identified by HM Treasury, for example in the 2022 Review of the UK’s anti-money laundering and counter-terrorist financing regulatory and supervisory regime. This review found that, while the core requirements of the regulations were mostly fit for purpose, there were potentially a number of technical changes that could be made to increase effectiveness and ensure proportionality for both regulated firms and customers.
The consultation also includes issues put forward by key stakeholders, such as the anti-money laundering supervisors, the regulated industries and their representative bodies, which could reduce burdens and make the regulations more effective at tackling economic crime.
The consultation covers four core themes:
- Making customer due diligence more proportionate and effective
- Strengthening system coordination
- Providing clarity on scope of the MLRs
- Reforming registration requirements for the Trust Registration Service.
HM Treasury is keen to hear from a wide range of stakeholders in response to the consultation, including regulated businesses and their customers, supervisory bodies, law enforcement agencies, civil society organisations and members of the public. The consultation document sets out a number of ways to respond to the consultation. This includes answering the questions via this online form.
We encourage stakeholders to provide as much evidence as possible to help inform the government’s response. Please include facts and figures where possible to justify your responses, including estimates of the impact of proposed changes on your business or sector. Additional comments are welcomed on the impact (negative, positive or neutral) of any proposed changes on individuals with protected characteristics (https://www.gov.uk/discrimination-your-rights) or the environment/climate. This will help us to assess the impact of any changes made and ensure evidence-based policy decisions.
Cost of Compliance Survey
In parallel with this consultation, HM Treasury is running a survey on the cost of compliance with the MLRs. This will help us to understand better how regulated businesses comply with the regulations and to assess the impact of future changes to the MLRs. We are keen to receive responses from a wide range of regulated businesses, including large firms, SMEs and sole traders. You can see and respond to this survey here: https://www.smartsurvey.co.uk/s/5MI1PN/
Privacy notice
Any personally identifiable data provided e.g. email address, will be handled in line with the Treasury’s overarching privacy notice for this activity, which is in the consultation document LINK HERE.
Please refer to SmartSurvey’s privacy notice for information on how SmartSurvey will process any of your personal data as the host platform - https://www.smartsurvey.co.uk/company/privacy-policy