On 10 January, the EU’s 5th Money Laundering Directive came into force amending the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017.
The Legal Sector Affinity Group (LSAG) - which includes the Law Society and all of the legal sector supervisors named in the regulations – has published a summary of changes to the regulations to help firms comply with the new requirements.
- a duty to collect proof of registration for entities (e.g. trusts and companies)
- a duty to inform the registry of any discrepancies in their information
- changes to client due diligence and enhanced due diligence
LSAG is currently redrafting fuller updated guidance on the regulations. This will require the approval of HM Treasury and will be published in the coming months.
In the meantime, the current fuller guidance is available on our website.
There has been a short lead-in time between the MLR Regulations 2019 being laid in Parliament on 20 December, and the legislation coming into force. However, the legislation requires firms to be compliant from today.
The SRA has said they will take the limited time that firms have had to prepare for the new requirements into account in their enforcement work.
If you have any questions, contact our Practice Advice Service.