MLD4 and 2017 MLRs—customer due diligence checklist for financial services firms
MLD4 and 2017 MLRs—customer due diligence checklist for financial services firms

The following Financial Services guidance note provides comprehensive and up to date legal information covering:

  • MLD4 and 2017 MLRs—customer due diligence checklist for financial services firms
  • Which financial services firms do the CDD provisions of the 2017 MLRs apply to?
  • Emission allowance auctions
  • Payment services and electronic money
  • Carrying on business in the UK
  • Maximum annual turnover
  • When must CDD measures be applied?
  • Transfer of funds
  • Existing customers
  • Ongoing monitoring
  • more

STOP PRESS: On 10 January 2020, the Fifth Money Laundering Directive (EU) 2018/843 (MLD5) was transposed in the UK through changes made to the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, SI 2017/692 (MLRs) by the Money Laundering and Terrorist Financing (Amendment) Regulations 2019, SI 2019/1511. This Practice Note will be updated in due course in light of this development.

Brexit: As of exit day (31 January 2020) the UK is no longer an EU Member State. However, in accordance with the Withdrawal Agreement, the UK has entered an implementation period, during which it continues to be subject to EU law. This has an impact on this Practice Note.

The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, SI 2017/692 (2017 MLRs), which implement the Fourth Money Laundering Directive (EU) 2015/849 (MLD4) and the Second Wire Transfer Regulation (EU) 2015/847 (WTR2) in the UK, entered into force on 26 June 2017.

The 2017 MLRs are amended by the Money Laundering and Terrorist Financing (Miscellaneous Amendments) Regulations 2018, SI 2018/1337, which have effect from 10 January 2019.

The Fifth Money Laundering Directive (EU) 2018/843 (MLD5) which amends MLD4 was published in the Official Journal of the EU on 19 June 2018 and enters into force on 9 July 2018. Member States are