Someone asked me recently about grace. Not the spiritual kind, or indeed the physical – if there is a loose paving stone within a hundred yards, I will trip over it. No, what they were concerned about is the period of grace granted after the passing of new legislation, to allow those affected to catch up. Specifically he was talking about the UK’s imminent Money Laundering Regulations 2017, which we confidently (hah!) expect to come into being on 26 June 2017.
Of course, the main thing to bear in mind when planning ahead is that there is many a slip ‘twixt cup and lip. And this is doubly so at the moment, with all UK politicians jockeying for position with regard to both the General Election (on 8 June) and the Brexit negotiations. Personally (and you’ll keep this to yourself, I am sure) I don’t trust a word any of them says at the moment, with so much at stake. For my part, I have read the draft new Regs, and indeed the draft new Guidance Notes that flow from them, but I am changing nothing about what I say or what I write until it is set in stone. In my diary I have blanked out the whole of the week of 26 June to “update the piggies” – my suites of AML books – and I’m not touching them until then.
But back to grace. It has been so long – all but a decade – since we had an update to the Regs that I have, to be honest, forgotten. But I seem to remember that the word on the street (the street in question being Canary Wharf, home of the FCA) was that firms would be allowed six months to get themselves straight, before regulators would descend and expect to see the new standards in place and work well underway – if not completed – on remediation of client files. I know that some regulators and legislators read this blog, so can anyone put us straight? Is this an official acknowledgement (on which we can count) that things cannot be changed overnight, or simply an understanding between friends?