March 2, 2021

Volume XI, Number 61

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March 02, 2021

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March 01, 2021

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Updated Advisory Notice on Money Laundering and Terrorist Financing Controls in Higher Risk Jurisdictions Published by HM Treasury

On October 25, HM Treasury published an updated advisory notice on money laundering and terrorist financing controls in higher risk jurisdictions.

The Money Laundering, Terrorist Financing and Transfer of Funds (Information of the Payer) Regulations 2017 require firms to implement policies and procedures to prevent activities relating to money laundering and terrorist financing.

On October 19, the Financial Action Task Force (FATF) published two statements (found in Annex A and Annex B of the advisory notice) identifying jurisdictions with strategic deficiencies in their anti-money laundering and counter-terrorism financing regimes. In response to FATF’s statements, HM Treasury suggests that firms note the following:

  1. Consider the Democratic People’s Republic of Korea (North Korea) as a high-risk jurisdiction, and apply countermeasures and enhanced due diligence measures in accordance with the associated risks;

  2. Consider Iran as high risk and apply enhanced due diligence measures in accordance with the associated risks;

  3. Take appropriate actions, such as enhanced due diligence in high-risk situations, to minimize associated risks relating to the Bahamas, Botswana, Ethiopia, Ghana, Pakistan, Serbia, Sri Lanka, Syria, Trinidad and Tobago, Tunisia, and Yemen.

Additionally, at the time of the advisory notice’s publication, North Korea, Iran, Syria, Tunisia and Yemen are subject to financial sanctions which require firms to take additional measures.

The advisory notice is available here.

Details of the financial sanctions to be taken by firms in relation to specific, high-risk jurisdictions are available here.

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©2020 Katten Muchin Rosenman LLPNational Law Review, Volume VIII, Number 307
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John Ahern, Financial Attorney, London, Katten Law Firm
Partner

John Ahern, partner at Katten Muchin Rosenman UK LLP and head of the London Financial Services group, focuses his practice on banking, financial services, UK and European financial markets, and related regulations. His background in private practice and as in-house counsel at a global investment bank provides him with perspective on the unique regulatory issues facing the wholesale and private banking sectors. John advises multilateral trading facilities, broker-dealers and banks on trading, clearing and settlement as well as custody of securities—both physical and...

+44 (0) 20 7770 5253
Carolyn H. Jackson, International Attorney, Katten Muchin law firm
Partner

Carolyn Jackson is a partner in Katten Muchin Rosenman UK LLP and is a Registered Foreign Lawyer. She provides US financial regulatory legal advice to a broad range of market participants, including commercial banks, investment banks, investment managers, broker-dealers, electronic trading platforms, clearinghouses, trade associations and over-the-counter derivatives service providers.

Carolyn guides clients in the structuring and offering of complex securities, commodities and derivatives transactions and in complying with US securities and commodities laws...

+44 0 20 7776 7625
Nathaniel Lalone, Katten Muchin Law Firm, Financial Institutions Attorney
Senior Associate

Nathaniel Lalone, a partner at Katten Muchin Rosenman UK LLP, has a broad range of experience in the regulation of financial products and financial markets, and frequently provides regulatory and compliance advice to trading venues, clearing houses and buy-side firms active in the over-the-counter (OTC) derivatives, futures and securities markets. He is actively involved in advising clients on the implementation of MiFID 2 and MiFIR in the European Union as well as the international reach of US financial services regulation. He also has significant experience with structuring...

+44 0 20 7776 7629
Neil Robson, private equity fund managers counselor, Katten Law Firm, London
Partner

Neil Robson, a regulatory and compliance partner with Katten Muchin Rosenman LLP, focuses his practice on counseling hedge and private equity fund managers and other investment advisers on operational, regulatory and compliance issues. He regularly addresses Financial Conduct Authority (FCA) and EU authorization and compliance under both the EU Alternative Investment Fund Managers Directive (AIFM Directive) and MiFID, cross-border issues in the financial services sector, market abuse, anti-money laundering and regulatory capital requirements, formations and buyouts of...

44-0-20-7776-7666
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