Consultation on AML/CFT Handbook amendments

We have proposed some changes to the AML/CFT Handbook. These changes are intended to:

provide further clarity and guidance to Industry
demonstrate compliance with the Financial Action Task Force’s Recommendations and Immediate Outcomes.

Please provide your feedback via the questions set out below.

It is the policy of the JFSC to make the content of all responses available for public inspection (unless specifically requested otherwise by the respondent). Please let us know at the end of this survey if you would like your responses to remain anonymous

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Do you consider the proposed Code of Practice and supporting guidance at Section 2.5 to be appropriate and proportionate? If not, please provide further detail in the comments section of this question.

Yes

Comments:

This is required

Do you consider the proposed guidance notes at Section 2.3.1 to be adequate for the purposes of your business? If not, please provide further detail in the comments section of this question.

Yes

Comments:

This is required

Do you consider the proposed Code of Practice and supporting guidance at Section 3.3 to be appropriate and proportionate? If not, please provide further detail in the comments section of this question.

Yes

Comments:

This is required

Do you consider the proposed guidance notes at Sections 3.3, 3.3.4.1 and 3.5 to be adequate for the purposes of your business? If not, please provide further detail in the comments section of this question.

Yes

Comments:

This is required

Do you consider the proposed guidance notes at Section 4.9 to be adequate for the purposes of your business? If not, please provide further detail in the comments section of this question.

Yes

Comments:

This is required

Do you consider the proposed guidance notes at Section 4.4.6 to be adequate for the purposes of your business? If not, please provide further detail in the comments section of this question.

Yes

Comments:

This is required

Do you consider the proposed Code of Practice and supporting guidance at Section 6.2 to be appropriate and proportionate? If not, please provide further detail in the comments section of this question.

Yes

Comments:

This is required

Do you consider the proposed guidance notes at Section 6.2, 6.2.1 and 6.3 to be adequate for the purposes of your business? If not, please provide further detail in the comments section of this question.

Yes

Comments:

This is required

Have you identified any unintended consequences of the new Glossary definitions proposed above? If so, please provide further detail in the comments section of this question.

Yes

Comments:

This is required

Do you consider the proposed guidance notes at Sections 7.1, 7.3 and 7.6.2 to be adequate for the purposes of your business? If not, please provide further detail in the comments section of this question.

Yes

Comments:

This is required

Do you consider the proposed amendments to the Codes of Practice at Sections 8.3.1 and 8.3.2 to be appropriate and proportionate? If not, please provide further detail in the comments section of this question.

Yes

Comments:

This is required

Do you consider the proposed Codes of Practice and supporting guidance notes at Section 9.2 to be appropriate and proportionate? If not, please provide further detail in the comments section of this question.

Yes

Comments:

This is required

Do you think that examples of changes in an employee’s circumstances which increase the risk of them being involved in money laundering, terrorist financing or a predicate offence of the same should be provided in Section 9.2? If so, please provide your suggestions in the comments section of this question.

Yes

Comments:

This is required

Do you consider the proposed Code of Practice and supporting guidance at Section 10.2 to be appropriate and proportionate? If not, please provide further detail in the comments section of this question.

Yes

Comments:

This is required

Have you identified any unintended consequences of removing the guidance note at Section 10.2 paragraph 5? If so, please provide further detail in the comments section of this question.

Yes

Comments:

This is required

Do you consider the proposed guidance notes at Sections 10.4.4 to be adequate for the purposes of your business? If not, please provide further detail in the comments section of this question.

Yes

Comments:

This is required

Do you consider the amended guidance notes at Section 15.3.1.8 to be adequate for the purposes of your business? If not, please provide further detail in the comments section of this question.

Yes

Comments:

This is required

Do you consider the amended guidance notes at Section 16.2.1.1 to be adequate for the purposes of your business? If not, please provide further detail in the comments section of this question.

Yes

Comments:

This is required

It is the policy of the JFSC to make the content of all responses available for public inspection (unless specifically requested otherwise by the respondent). Please let us know if you would like your responses to remain anonymous.

Yes

Full name, company and e-mail address:

This is required

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Do you consider the proposed Code of Practice and supporting guidance at Section 2.5 to be appropriate and proportionate? If not, please provide further detail in the comments section of this question.

Do you consider the proposed guidance notes at Section 2.3.1 to be adequate for the purposes of your business? If not, please provide further detail in the comments section of this question.

Do you consider the proposed Code of Practice and supporting guidance at Section 3.3 to be appropriate and proportionate? If not, please provide further detail in the comments section of this question.

Do you consider the proposed guidance notes at Sections 3.3, 3.3.4.1 and 3.5 to be adequate for the purposes of your business? If not, please provide further detail in the comments section of this question.

Do you consider the proposed guidance notes at Section 4.9 to be adequate for the purposes of your business? If not, please provide further detail in the comments section of this question.

Do you consider the proposed guidance notes at Section 4.4.6 to be adequate for the purposes of your business? If not, please provide further detail in the comments section of this question.

Do you consider the proposed Code of Practice and supporting guidance at Section 6.2 to be appropriate and proportionate? If not, please provide further detail in the comments section of this question.

Do you consider the proposed guidance notes at Section 6.2, 6.2.1 and 6.3 to be adequate for the purposes of your business? If not, please provide further detail in the comments section of this question.

Have you identified any unintended consequences of the new Glossary definitions proposed above? If so, please provide further detail in the comments section of this question.

Do you consider the proposed guidance notes at Sections 7.1, 7.3 and 7.6.2 to be adequate for the purposes of your business? If not, please provide further detail in the comments section of this question.

Do you consider the proposed amendments to the Codes of Practice at Sections 8.3.1 and 8.3.2 to be appropriate and proportionate? If not, please provide further detail in the comments section of this question.

Do you consider the proposed Codes of Practice and supporting guidance notes at Section 9.2 to be appropriate and proportionate? If not, please provide further detail in the comments section of this question.

Do you consider the proposed Code of Practice and supporting guidance at Section 10.2 to be appropriate and proportionate? If not, please provide further detail in the comments section of this question.

Have you identified any unintended consequences of removing the guidance note at Section 10.2 paragraph 5? If so, please provide further detail in the comments section of this question.

Do you consider the proposed guidance notes at Sections 10.4.4 to be adequate for the purposes of your business? If not, please provide further detail in the comments section of this question.

Do you consider the amended guidance notes at Section 15.3.1.8 to be adequate for the purposes of your business? If not, please provide further detail in the comments section of this question.

Do you consider the amended guidance notes at Section 16.2.1.1 to be adequate for the purposes of your business? If not, please provide further detail in the comments section of this question.

It is the policy of the JFSC to make the content of all responses available for public inspection (unless specifically requested otherwise by the respondent). Please let us know if you would like your responses to remain anonymous.