Reminder: High-risk countries for money laundering purposes: Enhanced Due Diligence
IPA Insolvency Practitioner newsletter, March 2023
Contents
- Paul Smith, CEO
- Samantha Keen, President
- NCA Amber Alert: High Net Worth Individuals and Tax Evasion (member login required to view)
- FCA warnings: Impersonation, unauthorised firms and unsolicited emails
- 2023 Annual Conference programme announced – places selling fast! (CPD: 6h)
- Latest Developments in Personal Insolvency: New SIP 3.1 and What this Means for You (CPD: 1.5h)
- 2023 Roadshow Series schedule released – reserve your place now! (CPD: 3h/4h)
- Bookings are open for the 15th Personal Insolvency Conference (CPD: 6h)
- IPA examinations update
- Discounted meeting facilities from Office Space in Town (member login required to view)
- Save money on your airport parking with APH! (Member login required to view)
- Need new IT products? Claim exclusive IPA membership offers from Dell
- CPI training with BPP – special offer for IPA members (member login required to view)
- Make savings on essential CPD with exclusive discounts on training from the IPA and our partners
- International Women’s Day celebrations
- IPA exclusive industry update from Insolvency Insider
Regulation 33(1)(b) of the 2017 Money Laundering Regulations requires any relevant person (i.e. an IP) to apply enhanced due diligence (EDD) measures where there is “… any business relationship… with a person established in a high-risk third country or in relation to any relevant transaction where either of the parties to the transaction is established in a high-risk third country“.
If you wish to check if any business relationship – or more likely a relevant transaction – is with a party in a high-risk third country, HM Treasury publish a list of countries deemed to be a high-risk. On 14 November 2022, HM Treasury published the ‘Money Laundering and Terrorist Financing (High-Risk Countries) Amendment (No.3) Regulations 2022. A copy can be found here. The list of countries can also be found in Schedule 3ZA of the 2017 Money Laundering Regulations and this will show that Gibraltar has recently been added to the list of high-risk third countries.
Members should continue to be aware of the risks of money laundering to their business from overseas criminals and parties, ensure that overseas matters are flagged as high-risk matters on your Reg 18 Firm Risk Assessment and ensure that staff are aware that if they have any overseas issues, to ensure that these are flagged, so initial checks can be made to confirm whether and what EDD is required.