In its consultation on the ML Regs (see yesterday’s blog post), HMT says at several points that it is keen for the UK not to “gold-plate” the EU legislation. Since when did gold-plating become a bad thing – except in comparison with the solid gold variety (which is not the comparison being made by HMT)? I realise that this is not an approach generated by or limited to HMT – it’s a UK government-wide stance – but I feel rather ashamed of it.
What the phrase means is that the UK is not willing to go above and beyond the requirements of EU legislation – even in instances where it would quite obviously be the right (sensible, moral) thing to do. A prime example is the definition of Politically Exposed Persons. Under EU legislation, PEPs are always foreign – the concept of the “domestic PEP” is not recognised in the legislation. And yet everyone knows – we in the UK more than most – that domestic PEPs are no more immune to the temptations of corruption than foreign ones. The sensible thing would be to amend the definition of a PEP in the ML Regs to include home-grown ones – but to do so would gold-plate the EU definition and might therefore put us at a competitive disadvantage (I assume that this is the argument against gold-plating).
There is no hiding the fact that the UK is a major money laundering destination. And if we cannot step out and make the most sensible and effective changes to alter that – regardless of whether they go further than other people have done – wouldn’t that be the right thing to do?
I hate money laundering 
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