Happy New Year – And Happy New AML Compliance
From the 10th January 2020, the 5th Money Laundering Directive (5MLD) will come into force.
In support of these new compliance requirements, By Lawyers has made several precedent amendments.
In particular the Client Details and Verifying Identity precedent now recommends an electronic identification verification process but continues to support a manual process should that be necessary. Practitioners can elect whether the client has passed the verification successfully or whether the client details have been passed on to the AML Officer for enhanced due diligence. For manual verification practitioners are able to record an acknowledgment that identity documents were produced personally, and the photographic ID was a good likeness of the person producing them.
Other changes include:
In support of these new compliance requirements, By Lawyers has made several precedent amendments.
In particular the Client Details and Verifying Identity precedent now recommends an electronic identification verification process but continues to support a manual process should that be necessary. Practitioners can elect whether the client has passed the verification successfully or whether the client details have been passed on to the AML Officer for enhanced due diligence. For manual verification practitioners are able to record an acknowledgment that identity documents were produced personally, and the photographic ID was a good likeness of the person producing them.
Other changes include:
- The precedent now captures sex and nationality detail; and
- Politically exposed persons (PEP) are covered in greater depth with a number of suggested searches firms should be undertaking. The details about a PEP client can be recorded on the precedent along with the provision for a senior partner to authorise the firm to act.
