Welcome back, one and all. Well, wasn’t that an exciting festive period? Just as I was undoing the top button on my skirt, ready to launch into the yard of Jaffa Cakes that my husband (he knows me so well) had bought, HMG had a little unexpected present for me: the Money Laundering and Terrorist Financing (Amendment) Regulations 2019. Yes, this piece of legislation is the UK’s response to the European Fifth Money Laundering Directive, as it serves to amend the current 2017 Regs to bring them into line with MLD5. Yes, it was published at about 4pm on Friday 20 December 2019. And yes, the requirement is to meet the deadline for compliance with MLD5… which is 10 January 2020. The day after tomorrow.
“Leave well alone,” counselled my husband, laying a trail of Jaffa Cakes from my office, across the garden and into the festively-decorated house. “No-one will notice anything until the new year.” But I am constitutionally incapable of leaving anything well alone, and particularly not anything to do with my AML-ish endeavours. And so I spent the evening of that Friday and the whole of the pre-Christmas weekend on three tasks:
- Taking the new amendment Regs and cutting and pasting them into the 2017 Regs to create a Frankenstein-ish tracked changes version
- Going through the changes very slowly to create my own crib sheet of what had altered
- [This was the biggie] Removing all the UK piggy books (that’s five staff versions and one version for NEDs) from sale on Amazon and updating them all to reflect the changes and reformatting them all and republishing them.
The result, dear readers, is that as you return to your desks this week, refreshed of mind and enlarged of tum, the UK piggies are waiting for you, fully updated and ready to lead your staff through the thrills and spills of the amended Regs. You can find purchase links to the staff versions here, and the NEDs version here. Happy new year to everyone (except money launderers – I hope you rot).
Your blog posts are great, love the tone, humour and content. Always quick to read with simple take away messages. Thank you 🙂
Thank you for your comment, Angela, and welcome to the blog. I can take compliments until the cows come home. And I always have MLROs and other compliance-y people in mind when I write: what do you need to know/do, and what can I do to help? Happy reading!
Happy New Year! I do hope you found time to catch up with those Jaffa cakes.
Thank you, Patersonloarn, and welcome to the blog. One quarter yard of Jaffa Cakes have already mysteriously disappeared…
What are your thoughts on Art Dealers being brought into scope?
Long time reader, first time poster!
Welcome to the blog, David! Now, art dealers (or, as the legislation has it, “art market participants”). I cannot see any logical reason why they should be brought into the AML family while jewellers, car dealers, yacht dealers, etc. are left in the limbo-land of high value dealers. Personally, I think they should all come in. (Did anyone see that recent Channel 4 documentary on “Diamond Dealers and Cockney Geezers”? Now that’s alarming stuff – and not just the jaw-dropping bling they sell: https://www.channel4.com/programmes/diamond-dealers-and-cockney-geezers).
The only reason I can see for MLD5 limiting it to art dealers is that it’s a toe in the water: it’s allowing countries time to work out how to supervise – for AML purposes – businesses which are not licensed in any way or required to join a trade body. Once that has been solved, then I assume (hope…) that other luxury goods sellers will be brought into the fold.
Best wishes from Susan