Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017—for law firms
Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017—for law firms

The following Practice Compliance guidance note provides comprehensive and up to date legal information covering:

  • Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017—for law firms
  • Application
  • Risk assessment
  • Policies, controls and procedures
  • Client due diligence
  • Enforcement, offences and penalties

Forthcoming changes:The UK has voted to leave the EU and this will take place on exit day as defined in section 20 of the European Union (Withdrawal) Act 2018. This has implications for law firms. This Practice Note is likely to be affected. It will be updated as and when relevant implementing legislation is published. For more on Brexit, see Practice Notes: Brexit—anti-money laundering and counter-terrorist financing—law firms and Preparing for Brexit—key considerations and action planning—law firms.

The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017), SI 2017/692 form part of the UK's overall anti-money laundering and counter-terrorist financing regime. They came into force on 26 June 2017 and give effect to the Fourth Money Laundering Directive (4MLD). They set administrative requirements which run parallel to the criminal element of the anti-money laundering (AML) and counter-terrorist financing (CTF) regime contained in the Proceeds of Crime Act 2002 (POCA 2002) and the Terrorism Act 2000 (TA 2000). There is some overlap with this legislation.

For more on POCA 2002 and the TA 2000, see Practice Notes: Proceeds of Crime Act 2002—key information for law firms and Counter-terrorist financing—key information for law firms.

Application

The MLR 2017 apply to relevant persons acting in the course of business in the UK. Relevant persons are:

  1. credit institutions

  2. financial