4th Anti Money Laundering Directive - Are you subject to the new regulations?

RWA has received several questions recently about what needs to be done to comply with this new EU Directive.

The EU Directive will be transposed into UK law by the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (‘MLR 2017’), which replaces the Money Laundering Regulations 2007 (‘MLR 2007’).

The new UK Anti-Money Laundering Regulations came into force on 26th June 2017. Many of the changes that the MLR 2017 introduces can be seen as a development and enhancement of the existing requirements rather than a major diversion from the existing legislative and complimentary regulatory regime.

So, if you were subject to the 2007 regulations, then you will continue to be caught by the new version.

The 2017 regulations do not widen the scope of the directive to encompass more regulated firms.

So, as a general insurance broker, am I subject to the new regulations?

In short, No!

Mortgage and general insurance intermediaries and brokers are not covered by the MLR 2017, or by the provisions of Senior Management Arrangements, Systems and Controls (SYSC) specifically relating to money laundering (e.g. the requirement to appoint an MLRO).

However, firms are subject to the general requirements of SYSC and must, therefore, establish and maintain appropriate systems and controls, including controls to counter the risk that the firm may be used for financial crime; and to meet the requirements of the Proceeds of Crime Act 2002 to which they are subject.

There are a number of modules relating to financial crime on the AVIVA Development Zone to assist as well as templates within the Development Zone.

Financial Crime and related Cyber Crime are certainly matters close to the Regulator’s heart and they will be looking to the insurance broking profession to play its part in protecting the UK financial system.

RWA can assist with any Financial Crime review you wish to undertake. Please contact your RWA Business Manager or the helpdesk if you require any assistance.

Terence Clark


About the author

Terence is the Compliance Director at RWA. He has over 35 years' experience in the Financial Services environment, covering general insurance, investments and mortgages. Before joining RWA, Terence worked for a large PLC insurance brokerage in Manchester, overseeing some 20 acquisitions. He was made a Director of RWA in 2011 and has worked with insurance broking firms of all sizes across the UK. He has a particular interest in Financial Crime and the protecting the insurance broker. Terence is also Executive Chairman of the Association of Professional Compliance Consultants (APCC), the professional body for the compliance consultancy sector.

Terence Clark

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