Every provision of the instruments listed is accounted for.
Read the full scope statement
Each provision has a disposition (obligation mapped, contextual, outside scope, superseded, future or unresolved), and each mapped obligation has an independently reviewed plain-English explanation. FCA Handbook material (SYSC and the Financial Crime Guide) is copyright: the register shows a short excerpt of each provision with a link to the full text on the FCA Handbook. The Sanctions and Anti-Money Laundering Act 2018 is an enabling Act and places no duties on firms directly; the firm duties it enables are in the regulations made under it, such as the Money Laundering Regulations 2017 and the Russia (Sanctions) (EU Exit) Regulations 2019. For the Bribery Act 2010, the Criminal Finances Act 2017, the Economic Crime and Corporate Transparency Act 2023 and the Proceeds of Crime Act 2002, the register covers the sections named on each instrument, and every section in that range is accounted for. The failure-to-prevent offences are offences, not duties: the register records the offence as context and maps the prevention procedures defence as the control a firm builds. The Financial Crime Guide is covered in full: chapters 1 to 3 and chapters 4 to 8 with Annex 1. It is guidance, so a paragraph is recorded as an obligation only where its own text says what the FCA expects a firm to do; self-assessment questions, good and poor practice examples and case studies illustrate those expectations and are recorded as context. Each chapter names its own audience, and the register uses it: the insider dealing and market manipulation chapter, for example, applies only to banks and investment firms subject to SYSC 6.1.1R. One published table in the data security chapter (FCG 5.2.3A) heads its poor-practice list "Examples of good practice"; the explanation of that paragraph says which list is which. The Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2026 (SI 2026/102), the UK’s new regime for cryptoassets, are covered in full. They come fully into force on 25 October 2027. Since 25 February 2026 they have been in force only so that the FCA can make rules, give guidance and directions, and so that firms can apply for permission for the new cryptoasset activities. Their firm duties are therefore recorded as future duties with their start date, so a firm can plan for them. These include the ban on public offers outside the listed exceptions, disclosure-document content, the insider dealing, unlawful disclosure and market manipulation prohibitions, systems to prevent and detect market abuse and to report suspicious orders, public disclosure of inside information, insider lists, information sharing, whistleblowing procedures, and the notification an authorised firm must give the FCA when acting as a cryptoasset exchange provider or custodian wallet provider. The transitional notifications are recorded the same way. FCA and Treasury powers are outside scope; the exceptions to the public-offer ban and the defences to compensation liability are context. Chapters 1 to 4 of the JMLSG Guidance Part I are also covered: senior management responsibility (1.1 to 1.65), internal controls (2.1 to 2.24), the nominated officer and MLRO (3.1 to 3.49) and the risk-based approach (4.1 to 4.82, without Annexes 4-I to 4-III), and the first part of Chapter 5 on customer due diligence (sections 5.1 and 5.2, and paragraphs 5.3.1 to 5.3.91 of section 5.3, which end with the standard identification requirement for private individuals; paragraphs 5.3.92 onwards and sections 5.4 to 5.7 are not yet covered). Where the Guidance repeats a duty it has already stated, the repeat is recorded as context pointing to the paragraph where the duty is recorded, so each duty is counted once. The Guidance is industry guidance approved by the Treasury, not law: a paragraph is recorded as an obligation only where it says what a firm should do, and where it restates a legal duty the register links it to the Money Laundering Regulations or SYSC provision that holds the duty itself. Its margin citations that point to provisions not yet in the register (for example parts of SYSC 24 and 25 on the Senior Managers and Certification Regime, and SUP 16.23 on the annual financial crime report) are listed on each paragraph. The register shows short excerpts of the Guidance with a link to the published text. Four further sanctions regimes are covered in full: the Counter-Terrorism (International Sanctions) (EU Exit) Regulations 2019, the ISIL (Da'esh) and Al-Qaida (United Nations Sanctions) (EU Exit) Regulations 2019, the Iran (Sanctions) Regulations 2023 and the Iran (Sanctions) (Nuclear) (EU Exit) Regulations 2019. In each, the asset freeze and the bans on making funds or economic resources available bind everyone, reach entities a designated person owns or controls, and list the specific exceptions and licences that relax them. Under the ISIL and Al-Qaida regime a person is designated automatically for as long as the UN list names them, with no UK decision. Each regime has its own duty on relevant firms to report designated persons and breaches to the Treasury, covering the persons designated under that regime. The two Iran instruments are in force side by side and do not overlap: the 2023 Regulations deal with human rights and hostile activity (internal repression goods, interception and monitoring, and goods of strategic concern such as drone components), and the Nuclear Regulations deal with proliferation (military, missile and nuclear goods, arrangements that let Iranian persons take part in uranium mining and related commercial activity, and the ban on providing specialised financial messaging services, which binds the messaging provider rather than a bank sending its own payments). The financial services, funds and brokering limbs of the trade bans are recorded as obligations; the powers of the Secretary of State, the Treasury and enforcement officers, and the duties of ship masters, port operators and exporters, are outside scope. The Democratic People's Republic of Korea (Sanctions) (EU Exit) Regulations 2019 are also covered in full. Besides the asset freeze, they place duties on UK credit and financial institutions, meaning any firm with FSMA permission and any money service business: not to open accounts, correspondent relationships, joint ventures or ownership interests with DPRK banks (including their branches and subsidiaries anywhere, and banks abroad that DPRK persons own or control), to close any that exist, not to open accounts for DPRK diplomatic missions, and not to transact with DPRK banks. Transfers of funds to or from the DPRK are banned apart from small listed payments. A Treasury licence relaxes the prohibitions, but the duty to close existing relationships is relaxed only by a Treasury direction. A relevant firm that suspects proliferation financing in its business with a DPRK bank must report it to the National Crime Agency and hold the related payments until it has instructions; that is separate from the usual report of designated persons to the Treasury. The finance of trade in the regime's many goods categories is caught by specific bans for military, dual-use and weapons-related items and for gold, precious metals and diamonds, and by a general ban on financing any other trade with the DPRK. The Republic of Belarus (Sanctions) (EU Exit) Regulations 2019 are covered in full. Besides the asset freeze, they ban dealing in new securities and money-market instruments issued by the Belarusian state and Belarus-connected companies, new loans to them, insurance and reinsurance for the Belarusian state, and reserve-management services for the National Bank and Ministry of Finance. The securities, loan and insurance bans reach companies through majority or full ownership, not through control. The finance and brokering bans in the trade rules cover nine of the twelve export categories (not banknotes, luxury goods or tobacco industry goods) and the Belarusian import goods other than arms. Banks and bureaux may not pay out or exchange sterling or EU banknotes for people connected with Belarus beyond a £10,000 traveller allowance, and may not buy Belarusian gold as principal. The duties on social media, internet access and app store providers to block designated persons, enforced by OFCOM, and the designated person's own duty to report its assets, are outside scope. Chapter 19 (Financial crime) of the FCA’s “Payment Services and Electronic Money - Our Approach” is also covered in full. It is the only chapter of that document about anti-money laundering, counter-terrorist financing or financial-crime controls; the chapter on operational and security risks deals with fraud and IT resilience and is not covered. The chapter is FCA guidance addressed to payment service providers and e-money issuers, including small payment and small e-money institutions. Where it restates a legal duty, such as the Money Laundering Regulations duties on policies and procedures and on appointing a compliance officer, the register links it to that provision rather than counting the duty again. Its own expectations are recorded as obligations: financial-crime systems and controls, the risk factors to weigh, risk-sensitive ongoing due diligence and acceptable-use policies, extra risk mitigation for merchant customers, regular review of anti-money laundering policies, managing the financial crime risk that comes from agents, distributors and outsourced providers, the knowledge, authority and resources of the compliance officer, and having regard to the FCA’s guidance on politically exposed persons. Its explanation of when required customer communications are not tipping off is recorded as context, and the FCA’s enforcement powers are outside scope.
Source versions and currentness Retained editions
31 instruments have a recorded version label.
Version labels describe retained source editions; they do not by themselves confirm currentness.
Sources and rights 31 instruments
The Republic of Belarus (Sanctions) (EU Exit) Regulations 2019SI 2019/600Text as at 1 October 2026Source rights: Crown copyright, Open Government Licence v3.0
Bribery Act 2010, sections 7 to 9 (failure of commercial organisations to prevent bribery)2010 c. 23Text as at 1 October 2026Source rights: Crown copyright. Contains public sector information licensed under the Open Government Licence v3.0 (https://www.nationalarchives.gov.uk/doc/open-government-licence/version/3/).
Counter-Terrorism Act 2008, Schedule 7 - terrorist financing, money laundering and proliferation (Treasury directions)2008 c. 28Text as at 1 October 2026Source rights: Crown copyright. Contains public sector information licensed under the Open Government Licence v3.0 (https://www.nationalarchives.gov.uk/doc/open-government-licence/version/3/).
Criminal Finances Act 2017, Part 3 (ss.44-52) - corporate offences of failure to prevent facilitation of tax evasion2017 c. 22Text as at 1 October 2026Source rights: Crown copyright. Contains public sector information licensed under the Open Government Licence v3.0 (https://www.nationalarchives.gov.uk/doc/open-government-licence/version/3/).
The Counter-Terrorism (International Sanctions) (EU Exit) Regulations 2019SI 2019/573Text as at 1 October 2026Source rights: Crown copyright, Open Government Licence v3.0
The Democratic People's Republic of Korea (Sanctions) (EU Exit) Regulations 2019SI 2019/411Text as at 1 October 2026Source rights: Crown copyright, Open Government Licence v3.0
Economic Crime and Corporate Transparency Act 2023, sections 188 to 193 (information sharing to prevent economic crime: civil liability protections) and sections 199 to 206 (failure to prevent fraud)2023 c. 56Text as at 1 October 2026Source rights: Crown copyright. Contains public sector information licensed under the Open Government Licence v3.0 (https://www.nationalarchives.gov.uk/doc/open-government-licence/version/3/).
The Electronic Money Regulations 2011SI 2011/99Text as at 1 October 2026Source rights: Crown copyright. Contains public sector information licensed under the Open Government Licence v3.0 (https://www.nationalarchives.gov.uk/doc/open-government-licence/version/3/).
FCA Approach Document 'Payment Services and Electronic Money - Our Approach', Chapter 19 (Financial crime)Payment Services and Electronic Money - Our Approach, Chapter 19May 2026 (version 8)Source rights: FCA copyright material, not Crown copyright and not licensed under the Open Government Licence. The register shows a short excerpt of each paragraph with a link to the published Approach Document.
FCA Handbook: Senior Management Arrangements, Systems and Controls (SYSC) - compliance function and financial crime systems and controls (SYSC 3.2.6, 6.1, 6.3)FCA Handbook SYSC 3.2.6-3.2.6K, 6.1, 6.3Text as at 1 October 2026Source rights: FCA Handbook content is not covered by the Open Government Licence. Reproduced here as a short excerpt with a link to the official source; see publicTextPolicy.
FCA Financial Crime Guide (FCG): Chapter 1 (Introduction), Chapter 2 (Governance), Chapter 3 (Money laundering and terrorist financing)FCA Financial Crime Guide FCG 1-3Text as at 1 October 2026Source rights: FCA Financial Crime Guide content is not covered by the Open Government Licence. Reproduced here as a short excerpt with a link to the official source; see publicTextPolicy.
FCA Financial Crime Guide (FCG), chapters 4-8 and Annex 1 (fraud, data security, bribery and corruption, sanctions and proliferation financing, insider dealing and market manipulation; common terms)FCGText as at 1 October 2026Source rights: FCA copyright material, not Crown copyright; not licensed under the Open Government Licence.
The Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2026 (SI 2026/102)SI 2026/102Text as at 1 October 2026Source rights: Crown copyright, Open Government Licence v3.0
Regulation (EU) 2015/847 of the European Parliament and of the Council of 20 May 2015 on information accompanying transfers of funds and repealing Regulation (EC) No 1781/2006, as it forms part of UK domestic lawRegulation (EU) 2015/847Text as at 30 June 2026Source rights: Crown copyright. Contains public sector information licensed under the Open Government Licence v3.0 (https://www.nationalarchives.gov.uk/doc/open-government-licence/version/3/).
The Iran (Sanctions) (Nuclear) (EU Exit) Regulations 2019SI 2019/461Text as at 1 October 2026Source rights: Crown copyright, Open Government Licence v3.0
The Iran (Sanctions) Regulations 2023SI 2023/1314Text as at 1 October 2026Source rights: Crown copyright, Open Government Licence v3.0
The ISIL (Da'esh) and Al-Qaida (United Nations Sanctions) (EU Exit) Regulations 2019SI 2019/466Text as at 1 October 2026Source rights: Crown copyright, Open Government Licence v3.0
JMLSG Guidance Part I: Prevention of money laundering / combating terrorist financing, Chapter 1 (Senior management responsibility)JMLSG Guidance Part I, Chapter 12023 revised version, updated August 2025Source rights: JMLSG copyright material, not Crown copyright and not licensed under the Open Government Licence. The register shows a short excerpt of each paragraph with a link to the published Guidance.
JMLSG Guidance Part I: Prevention of money laundering / combating terrorist financing, Chapter 2 (Internal controls)JMLSG Guidance Part I, Chapter 22023 revised version, updated August 2025Source rights: JMLSG copyright material, not Crown copyright and not licensed under the Open Government Licence. The register shows a short excerpt of each paragraph with a link to the published Guidance.
JMLSG Guidance Part I: Prevention of money laundering / combating terrorist financing, Chapter 3 (Nominated officer/MLRO)JMLSG Guidance Part I, Chapter 32023 revised version, updated August 2025Source rights: JMLSG copyright material, not Crown copyright and not licensed under the Open Government Licence. The register shows a short excerpt of each paragraph with a link to the published Guidance.
JMLSG Guidance Part I: Prevention of money laundering / combating terrorist financing, Chapter 4 (Risk-based approach)JMLSG Guidance Part I, Chapter 42023 revised version, updated August 2025Source rights: JMLSG copyright material, not Crown copyright and not licensed under the Open Government Licence. The register shows a short excerpt of each paragraph with a link to the published Guidance.
JMLSG Guidance Part I: Prevention of money laundering / combating terrorist financing, Chapter 5 (Customer due diligence), part aJMLSG Guidance Part I, Chapter 52023 revised version, updated August 2025Source rights: JMLSG copyright material, not Crown copyright and not licensed under the Open Government Licence. The register shows a short excerpt of each paragraph with a link to the published Guidance.
The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017SI 2017/692Text as at 30 June 2026Source rights: Crown copyright. Contains public sector information licensed under the Open Government Licence v3.0 (https://www.nationalarchives.gov.uk/doc/open-government-licence/version/3/).
The Money Laundering and Terrorist Financing (Amendment) Regulations 2026SI 2026/621Text as at 21 July 2026Source rights: Crown copyright. Contains public sector information licensed under the Open Government Licence v3.0 (https://www.nationalarchives.gov.uk/doc/open-government-licence/version/3/).
Proceeds of Crime Act 2002, Part 7 (Money Laundering), sections 327 to 340, with Schedule 9 (Regulated Sector and Supervisory Authorities)2002 c.29, Part 7 (ss.327-340) and Schedule 9Text as at 30 June 2026Source rights: Crown copyright. Contains public sector information licensed under the Open Government Licence v3.0 (https://www.nationalarchives.gov.uk/doc/open-government-licence/version/3/).
Proceeds of Crime Act 2002, Part 8 (Investigations), Chapters 1, 2 and 4 - England and Wales and Northern Ireland: production, disclosure, customer information and account monitoring orders, search and seizure warrants, and unexplained wealth orders (ss.341-379, 412A-416)2002 c. 29Text as at 1 October 2026Source rights: Crown copyright. Contains public sector information licensed under the Open Government Licence v3.0 (https://www.nationalarchives.gov.uk/doc/open-government-licence/version/3/).
The Payment Services Regulations 2017SI 2017/752Text as at 1 October 2026Source rights: Crown copyright. Contains public sector information licensed under the Open Government Licence v3.0 (https://www.nationalarchives.gov.uk/doc/open-government-licence/version/3/).
The Russia (Sanctions) (EU Exit) Regulations 2019SI 2019/855Text as at 1 October 2026Source rights: Crown copyright. Contains public sector information licensed under the Open Government Licence v3.0 (https://www.nationalarchives.gov.uk/doc/open-government-licence/version/3/).
Sanctions and Anti-Money Laundering Act 20182018 c.13Text as at 1 October 2026Source rights: Crown copyright. Contains public sector information licensed under the Open Government Licence v3.0 (https://www.nationalarchives.gov.uk/doc/open-government-licence/version/3/).
Terrorism Act 2000, Part III (Terrorist Property), sections 14 to 31 (including 17A, 21ZA to 21ZC and 21A to 21H)2000 c.11, Part III (ss.14-31)Text as at 30 June 2026Source rights: Crown copyright. Contains public sector information licensed under the Open Government Licence v3.0 (https://www.nationalarchives.gov.uk/doc/open-government-licence/version/3/).
Terrorism Act 2000, Schedules 6 and 6A - financial information orders and account monitoring orders2000 c. 11Text as at 1 October 2026Source rights: Crown copyright. Contains public sector information licensed under the Open Government Licence v3.0 (https://www.nationalarchives.gov.uk/doc/open-government-licence/version/3/).
UK sanctions regulations other than the Russia, Belarus, Counter-Terrorism, ISIL (Da'esh) and Al-Qaida, Iran and North Korea (DPRK) regimes, including Syria, Myanmar, Libya, Afghanistan, Cyber, Chemical Weapons, Global Human Rights and Global Anti-Corruption
JMLSG Guidance Part I Chapter 5 (customer due diligence), paragraphs 5.3.92 onwards and sections 5.4 to 5.7, Chapters 6 to 8 (suspicious activity reporting, staff training and record keeping) with their annexes, Annexes 4-I to 4-III to Chapter 4, the Glossary and Appendices I and II, and the Part II sector chapters (retail banking, wealth management, e-money, money transmission and cryptoassets)
Official guidance on the failure-to-prevent offences: HMRC guidance on preventing the facilitation of tax evasion, Home Office guidance on failure to prevent fraud, and the Ministry of Justice guidance on the Bribery Act
Proceeds of Crime Act 2002 Part 8 Chapter 3 (sections 380 to 412): the Scottish equivalents of the investigation orders
Economic Crime and Corporate Transparency Act 2023 sections 196 to 198: attribution of criminal liability for economic crimes through senior managers
The FCA rules and guidance made under the Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2026, including the designated activity rules for cryptoasset public offers, admissions to trading and market abuse
The other 19 chapters and 5 annexes of the FCA’s “Payment Services and Electronic Money - Our Approach” (authorisation and registration, safeguarding, conduct of business, operational and security risks, authentication and others)
Counter-Terrorism Act 2008 Schedule 7 · Counter-Terrorism Act 2008, Sch.7 para.10Where a direction imposes this requirement, a relevant person must undertake enhanced customer due diligence (establishing identity,…Credit institutionFinancial institution+3Obligation mapped
Plain English
Where a direction imposes this requirement, a relevant person must undertake enhanced customer due diligence (establishing identity, obtaining information about the designated person and the source of their funds, and assessing relevant risk) before and during a transaction or business relationship with the designated person.
Obligation
Where a direction imposes this requirement, a relevant person must undertake enhanced customer due diligence measures - establishing the designated person’s identity, obtaining information about them and the source of their funds, and assessing the risk of their involvement in terrorist financing, money laundering or weapons-proliferation activity - before entering into, and during, a transaction or business relationship with the designated person.
VerifyAssess
Data items: designated person’s identity, business and source-of-funds information
A direction may require a relevant person to undertake enhanced customer due diligence measures— a before entering into a transaction or business relationship with a designated person, and b during a business relationship with such a person
Only where a Treasury direction under this Schedule imposing this requirement is in force and applies to the firm (as a particular person, a described class or all persons operating in the financial sector: a credit or financial institution that is a UK person or acting in the course of business carried on in the UK).
Exceptions
Cannot be imposed on a person operating in the financial sector only by virtue of paragraph 5(2)(g) (certain insurance companies).
Source wording and supporting evidenceOriginal text
10 1 A direction may require a relevant person to undertake enhanced customer due diligence measures— a before entering into a transaction or business relationship with a designated person, and b during a business relationship with such a person. 2 The direction may do either or both of the following— a impose a general obligation to undertake enhanced customer due diligence measures; b require a relevant person to undertake specific measures identified or described in the direction. 3 “ Customer due diligence measures ” means measures to— a establish the identity of the designated person, b obtain information about— i the designated person and their business, and ii the source of their funds, and c assess the risk of the designated person being involved in relevant activities. 4 In sub-paragraph (3)(c) “ relevant activities ” means— a terrorist financing; b money laundering; or c the development or production of nuclear, radiological, biological or chemical weapons or the facilitation of that development or production. 5 A direction may not impose requirements of a kind mentioned in this paragraph on a person who is regarded as operating in the financial sector by virtue only of paragraph 5(2)(g) (certain insurance companies).
Counter-Terrorism Act 2008 Schedule 7 · Counter-Terrorism Act 2008, Sch.7 para.11Where a direction imposes this requirement, a relevant person must keep customer due diligence information up to date and scrutinise…Credit institutionFinancial institution+3Obligation mapped
Plain English
Where a direction imposes this requirement, a relevant person must keep customer due diligence information up to date and scrutinise transactions in a business relationship with a designated person to check they are consistent with what is known about the person and their business.
Obligation
Where a direction imposes this requirement, a relevant person must undertake enhanced ongoing monitoring of a business relationship with a designated person: keeping due-diligence information and documents up to date, and scrutinising transactions (including, where appropriate, their source of funds) to check they are consistent with the relevant person’s knowledge of the designated person and their business.
AssessRetain records
Data items: ongoing transaction and due-diligence information on the designated person
A direction may require a relevant person to undertake enhanced ongoing monitoring of any business relationship with a designated person
Only where a Treasury direction under this Schedule imposing this requirement is in force and applies to the firm (as a particular person, a described class or all persons operating in the financial sector: a credit or financial institution that is a UK person or acting in the course of business carried on in the UK).
Exceptions
Cannot be imposed on a person operating in the financial sector only by virtue of paragraph 5(2)(g) (certain insurance companies).
Source wording and supporting evidenceOriginal text
11 1 A direction may require a relevant person to undertake enhanced ongoing monitoring of any business relationship with a designated person. 2 The direction may do either or both of the following— a impose a general obligation to undertake enhanced ongoing monitoring; b require a relevant person to undertake specific measures identified or described in the direction. 3 “Ongoing monitoring” of a business relationship means— a keeping up to date information and documents obtained for the purposes of customer due diligence measures, and b scrutinising transactions undertaken during the course of the relationship (and, where appropriate, the source of funds for those transactions) to ascertain whether the transactions are consistent with the relevant person's knowledge of the designated person and their business. 4 A direction may not impose requirements of a kind mentioned in this paragraph on a person who is regarded as operating in the financial sector by virtue only of paragraph 5(2)(g) (certain insurance companies).
Approach Document (payments/e-money) ch.19 · Approach Doc 19.10To mitigate the risk of their products being used for money laundering or terrorist financing, the FCA expects PSPs and e-money issuers…Payment institutionE-money institutionObligation mapped
Plain English
To mitigate the risk of their products being used for money laundering or terrorist financing, the FCA expects PSPs and e-money issuers to apply ongoing due diligence to customers on a risk-sensitive basis (where applicable, under their existing MLR obligations), and to put in place and enforce policies on the acceptable use of their products.
Obligation
Apply risk-sensitive ongoing due diligence where applicable, and put in place and enforce acceptable-use policies for the firm's products.
Verify
we expect PSPs and e-money issuers to: • where applicable, apply ongoing due diligence to customers on a risk-sensitive basis in accordance with their obligations under the MLRs; and • put in place and enforce policies to determine the acceptable use of their products.
Applies to
Firm types
Payment institution, E-money institution
Business lines
Payments and e-money
Customer types
All customer types
Stages
Ongoing review
Conditions
Addressed to payment service providers and e-money issuers; in this document PIs and EMIs include small payment institutions and small e-money institutions. Banks and building societies that provide payment services or issue e-money are also within these terms, and SYSC 6.1.1R and SYSC 6.3 apply to them as well (paragraph 19.4).
Source wording and supporting evidenceOriginal text (excerpt)
As part of their risk assessment and to mitigate the risk of their products being used for money laundering or terrorist financing purposes, we expect PSPs and e-money issuers to: • where applicable, apply ongoing due diligence to customers on a risk-sensitive basis in…
FCA Financial Crime Guide 1-3 · FCG 2.2.4A firm should identify and assess its financial crime risks (products/services, jurisdictions, customer types, transaction…Credit institutionFinancial institution+4Obligation mapped
Plain English
A firm should identify and assess its financial crime risks (products/services, jurisdictions, customer types, transaction complexity/volume, distribution channels) so it can target resources; its business-wide risk assessment(s) should be comprehensive, draw on a wide range of information and be proportionate; individual-relationship risk assessments should build on it, inform the level of due diligence applied, and both should be reviewed regularly to stay current.
Obligation
Maintain a comprehensive, proportionate, regularly reviewed business-wide financial crime risk assessment, and build individual-relationship risk assessments on it.
AssessRetain records
A business-wide risk assessment – or risk assessments – should: • be comprehensive and consider a wide range of factors
FCG 2 applies to firms subject to SYSC 3.2.6R or SYSC 6.1.1R, to e-money and payment institutions within FCA supervisory scope (FCG 2.1.1G) and to Annex I financial institutions the FCA supervises under the MLRs (FCG 2.1.2G); FCG 1.1.5G adds MLR-registered cryptoasset businesses. Guidance: the binding duties are SYSC 3.2.6R / 6.1.1R and the MLRs.
Source wording and supporting evidenceOriginal text (excerpt)
A thorough understanding of its financial crime risks is key if a firm is to apply proportionate and effective systems and controls. A firm should identify and assess the financial crime risks to which it is exposed as a result of, for example, the products and services it…
FCA Financial Crime Guide 1-3 · FCG 3.2.7Firms must apply EDD and enhanced ongoing monitoring in higher-risk situations, including correspondent relationships with third-country…Credit institutionFinancial institution+3Obligation mapped
Plain English
Firms must apply EDD and enhanced ongoing monitoring in higher-risk situations, including correspondent relationships with third-country institutions (reg 34, senior management approval), PEPs/family members/known close associates (senior manager approval of the relationship), relationships or relevant transactions involving a FATF-listed high-risk third country (specified additional information and senior management approval), complex/unusually large/no-apparent-purpose transactions, and cryptoasset transactions showing privacy-enhancing techniques (mixers, privacy coins, self-hosted addresses) or blockchain-analysis exposure to criminal/sanctioned activity; the extent of EDD must be commensurate with, and the firm must be able to demonstrate it matches, the assessed risk.
Obligation
Apply enhanced due diligence and ongoing monitoring, with senior management approval, in the specified higher-risk situations (correspondent banking, PEPs, high-risk third countries, unusual/complex transactions, cryptoasset privacy-risk indicators), commensurate with assessed risk.
AssessVerifyAppoint a role
in higher risk situations, firms must apply enhanced due diligence and ongoing monitoring
Applies to
Firm types
Credit institution, Financial institution, Investment firm, E-money institution, Cryptoasset business
Business lines
All business lines
Customer types
All customer types
Stages
All stages
Conditions
FCG 3 applies to firms subject to SYSC 3.2.6A-J or SYSC 6.3, Annex I financial institutions and e-money institutions for which the FCA is MLR supervisor (FCG 3.1.1G), and MLR-registered cryptoasset businesses (FCG 1.1.5G); not to payment institutions, which HMRC supervises for MLR purposes (FCG 3.1.2G); less relevant to mortgage brokers and general insurers (FCG 3.1.3G). Guidance: the binding duties are in the MLRs and SYSC.
Source wording and supporting evidenceOriginal text (excerpt)
The law requires that firms’ anti-money laundering policies and procedures are sensitive to risks. This means that in higher risk situations, firms must apply enhanced due diligence and ongoing monitoring. Situations that present a higher money laundering risk might include, but…
FCA Financial Crime Guide 1-3 · FCG 3.2.8EDD must give a firm a greater understanding of the customer and risk than standard CDD, with the extent commensurate to assessed risk;…Credit institutionFinancial institution+3Obligation mapped
Plain English
EDD must give a firm a greater understanding of the customer and risk than standard CDD, with the extent commensurate to assessed risk; example EDD measures include more information on the customer’s/beneficial owner’s business, more robust identity verification, understanding reputation/public-life role, searches on corporate directors/controllers, and establishing legitimate source of wealth and source of funds.
Obligation
Apply EDD measures commensurate with assessed risk, drawing on the listed example steps (enhanced verification, reputation checks, source of wealth/funds establishment) appropriate to why the relationship was classified high-risk.
VerifyAssess
The extent of EDD must be commensurate to the risk associated with the business relationship or occasional transaction
Applies to
Firm types
Credit institution, Financial institution, Investment firm, E-money institution, Cryptoasset business
Business lines
All business lines
Customer types
All customer types
Stages
All stages
Conditions
FCG 3 applies to firms subject to SYSC 3.2.6A-J or SYSC 6.3, Annex I financial institutions and e-money institutions for which the FCA is MLR supervisor (FCG 3.1.1G), and MLR-registered cryptoasset businesses (FCG 1.1.5G); not to payment institutions, which HMRC supervises for MLR purposes (FCG 3.1.2G); less relevant to mortgage brokers and general insurers (FCG 3.1.3G). Guidance: the binding duties are in the MLRs and SYSC.
Source wording and supporting evidenceOriginal text (excerpt)
Firms must apply EDD measures in situations that present a higher risk of money laundering. EDD should give firms a greater understanding of the customer and their associated risk than standard due diligence. It should provide more certainty that the customer and/or beneficial…
FCG chapters 4-8 and Annex 1 · FCG 8.2.4Market Abuse Regulation monitoring results may be used to counter financial crime, but because the criminal offences cover different…Credit institutionInvestment firmObligation mapped
Plain English
Market Abuse Regulation monitoring results may be used to counter financial crime, but because the criminal offences cover different markets and instruments, firms should assess whether those arrangements can be relied on. Firms should regularly consider, through transaction, order and communications surveillance and client due diligence, whether employees or clients may be committing insider dealing or market manipulation, including where orders come from an underlying client. They should report suspicions by STOR and/or SAR (a STOR is required for suspicious employee trading), and should document the options for countering ongoing risk: enhanced due diligence and monitoring, restricting markets, services or leverage, disciplinary action, or ending the relationship.
Obligation
Assess whether Market Abuse Regulation surveillance can be relied on to monitor for the criminal insider dealing and market manipulation offences, and regularly consider whether employees or clients (including underlying clients) may be committing them. Report suspicions by STOR and/or SAR (a STOR is required for suspicious employee trading), and document the options for countering ongoing risk from the client or employee and when to use them.
AssessReport
Data items: order, transaction and communications surveillance results
Firms should therefore assess whether their arrangements to detect and report market abuse can be appropriately relied on to monitor for potential insider dealing and market manipulation
Applies to
Firm types
Credit institution, Investment firm
Business lines
Not recorded
Customer types
Not recorded
Stages
Not recorded
Conditions
FCG 8 applies only to firms subject to SYSC 6.1.1R (FCG 8.1.1G), and is aimed at firms that give clients or employees access to the markets to which the criminal insider dealing and market manipulation offences apply (FCG 8.1.6G). Guidance: the binding duty is SYSC 6.1.1R.
Source wording and supporting evidenceOriginal text (excerpt)
We recognise that the Market Abuse Regulation already imposes monitoring requirements on persons professionally arranging or executing transactions, in order to detect and report suspicious orders and transactions in the form of STORs (as well as imposing similar monitoring…
JMLSG Guidance Part I, Chapter 2 · JMLSG 2.19Where UK anti-money laundering work is done abroad by an outsourced provider or group company (such as call centres, transaction…Credit institutionFinancial institution+4Obligation mapped
Plain English
Where UK anti-money laundering work is done abroad by an outsourced provider or group company (such as call centres, transaction monitoring or customer due diligence processing), it must follow policies equivalent to the UK firm's, and all suspicions about UK accounts, transactions or activity must be reported to the firm's UK nominated officer.
Obligation
Where a firm's UK AML/CTF operational activities are undertaken by an outsourced service provider or group company in another jurisdiction, those activities must be subject to equivalent AML/CTF policies and procedures to the UK firm's own, and internal reporting procedures must ensure all suspicions relating to UK-related accounts, transactions or activities are reported to the firm's UK nominated officer.
those activities must be subject to equivalent AML/CTF policies and procedures that are applicable to the UK firm
JMLSG Part I guidance for the UK financial sector, which the Treasury has approved; it is not law. Where UK AML/CTF operational activities are undertaken by an outsourced provider or group company in another jurisdiction.
Source wording and supporting evidenceOriginal text (excerpt)
Where a firm's UK AML/CTF operational activities are undertaken by an outsourced service provider or group companies in other jurisdictions (e.g. call centres abroad, transaction monitoring or CDD processing), those activities must be subject to equivalent AML/CTF policies and…
JMLSG Guidance Part I, Chapter 3 · JMLSG 3.24A firm should take reasonable steps to give the nominated officer access to relevant business information before deciding on a report,…Credit institutionFinancial institution+4Obligation mapped
Plain English
A firm should take reasonable steps to give the nominated officer access to relevant business information before deciding on a report, such as the customer's or beneficial owner's financial circumstances, the features and location of transactions, and the underlying customer due diligence records and documents.
Obligation
A firm should take reasonable steps to give its nominated officer access to the relevant business information likely to be needed before deciding whether to make a report, which may include the financial circumstances of the customer or beneficial owner, the features of the relevant transactions, and the underlying CDD information and source documentation.
A firm should therefore take reasonable steps to give its nominated officer access to such information
Source wording and supporting evidenceOriginal text (excerpt)
In most cases, before deciding to make a report, the nominated officer is likely to need access to the firm’s relevant business information. A firm should therefore take reasonable steps to give its nominated officer access to such information. Relevant business information may…
JMLSG Guidance Part I, Chapter 4 · JMLSG 4.23In assessing risk, firms must take account of new products, business practices, delivery mechanisms and technologies; the assessment…Credit institutionFinancial institution+4Obligation mapped
Plain English
In assessing risk, firms must take account of new products, business practices, delivery mechanisms and technologies; the assessment should be done before launch, and appropriate measures, including enhanced due diligence where relevant, taken to manage the risks. The legal duty is in regulations 19(4)(c), 19A(4) and 33(6)(b)(v) of the Money Laundering Regulations 2017.
Obligation
In identifying and assessing ML/TF/PF risk, firms must take account of whether new products, new business practices, new delivery mechanisms, or new or developing technologies are involved; such a risk assessment should take place before the launch of the new product, practice or technology, with appropriate measures taken to manage and mitigate the risks, including enhanced due diligence where relevant.
firms must take account of whether new products and new business practices are involved, including new delivery mechanisms, and the use of new or developing technologies
Source wording and supporting evidenceOriginal text (excerpt)
In identifying and assessing the money laundering, terrorist financing and proliferation financing risks, firms must take account of whether new products and new business practices are involved, including new delivery mechanisms, and the use of new or developing technologies for…
JMLSG Guidance Part I, Chapter 4 · JMLSG 4.28The policies must cover at least risk management, customer due diligence, reporting, record keeping, internal controls, compliance…Credit institutionFinancial institution+4Obligation mapped
Plain English
The policies must cover at least risk management, customer due diligence, reporting, record keeping, internal controls, compliance management and employee screening, plus independent audit where appropriate and, for parent firms, sharing customer, account and transaction information within the group. The legal duties are in regulations 19, 19A, 20(1)(b) and 21 of the Money Laundering Regulations 2017.
Obligation
Make policies, controls and procedures cover at least risk management, customer due diligence, reporting, record keeping, internal controls, compliance management and employee screening; an independent audit function where appropriate; and, for parent firms, group information sharing.
The policies, controls and procedures referred to in paragraph 4.24 must include, but are not limited to: ➢ risk management practices, customer due diligence, reporting, record-keeping, internal controls, compliance management and employee screening
Source wording and supporting evidenceOriginal text (excerpt)
The policies, controls and procedures referred to in paragraph 4.24 must include, but are not limited to: ➢ risk management practices, customer due diligence, reporting, record-keeping, internal controls, compliance management and employee screening; ➢ where appropriate with…
JMLSG Guidance Part I, Chapter 4 · JMLSG 4.30Customer due diligence should let a firm reasonably believe it knows each customer's and beneficial owner's true identity and the…Credit institutionFinancial institution+4Obligation mapped
Plain English
Customer due diligence should let a firm reasonably believe it knows each customer's and beneficial owner's true identity and the business it will do; its procedures should identify and verify each customer promptly, take reasonable measures to verify beneficial owners, and gather enough information to understand the customer's business and expected transactions.
Obligation
The firm's procedures should include procedures to identify and verify the identity of each customer on a timely basis, to identify and take reasonable measures to verify the identity of any ultimate beneficial owner, and to obtain appropriate additional information to understand the customer's circumstances and business, including the expected nature and level of transactions.
The firm’s procedures should include procedures to: ➢ Identify and verify the identity of each customer on a timely basis ➢ Identify and take reasonable measures to verify the identity of any ultimate beneficial owner ➢ Obtain appropriate additional information to understand the…
Source wording and supporting evidenceOriginal text (excerpt)
The application of CDD measures is intended to enable a firm to form a reasonable belief that it knows the true identity of each customer and beneficial owner, and, with an appropriate degree of confidence, knows the types of business and transactions the customer is likely to…
JMLSG Guidance Part I, Chapter 4 · JMLSG 4.34Managing money laundering, terrorist financing and proliferation financing risk involves verifying identity, collecting information and…Credit institutionFinancial institution+4Obligation mapped
Plain English
Managing money laundering, terrorist financing and proliferation financing risk involves verifying identity, collecting information and monitoring activity, including decisions on electronic verification and reliance on other firms; firms must set the extent of customer due diligence on a risk-sensitive basis according to the customer, relationship, product or transaction. The legal duty itself is in regulation 28(12) of the Money Laundering Regulations 2017.
Obligation
Firms must determine the extent of their CDD measures on a risk-sensitive basis depending on the type of customer, business relationship, product or transaction.
Firms must determine the extent of their CDD measures on a risk-sensitive basis depending on the type of customer, business relationship, product or transaction
Source wording and supporting evidenceOriginal text (excerpt)
As regards money laundering, terrorist financing and proliferation financing, managing and mitigating the risks will involve measures to verify the customer’s identity; collecting additional information about the customer; and monitoring their transactions and activity, to…
JMLSG Guidance Part I, Chapter 4 · JMLSG 4.46When assessing customer, geographic, product, service, transaction and channel risks, a firm should take account of risk variables, such…Credit institutionFinancial institution+4Obligation mapped
Plain English
When assessing customer, geographic, product, service, transaction and channel risks, a firm should take account of risk variables, such as the purpose of the relationship, the size of assets or transactions and the regularity or length of the relationship, which can raise or lower risk and the due diligence needed.
Obligation
When assessing ML/TF/PF risks relating to customer types, countries/geographic areas, and products/services/transactions/delivery channels, a firm should take into account risk variables relating to those risk categories, which singly or in combination may increase or decrease the potential risk and so affect the appropriate level of CDD.
a firm should take into account risk variables relating to those risk categories
Source wording and supporting evidenceOriginal text (excerpt)
When assessing the ML/TF/PF risks relating to types of customers, countries or geographic areas, and particular products, services, transactions or delivery channel risks, a firm should take into account risk variables relating to those risk categories. These variables, either…
JMLSG Guidance Part I, Chapter 4 · JMLSG 4.62Where risk is higher, firms must apply enhanced due diligence matching it: in particular, examine the background and purpose of…Credit institutionFinancial institution+4Obligation mapped
Plain English
Where risk is higher, firms must apply enhanced due diligence matching it: in particular, examine the background and purpose of transactions as far as reasonably possible and increase monitoring. Other measures can include more information on the customer, beneficial owner and relationship, source of funds or wealth, reasons for transactions, senior management approval, closer monitoring, and requiring the first payment from an account in the customer's name at a bank with similar standards. The legal duty itself is in regulation 33(4) and (5) of the Money Laundering Regulations 2017.
Obligation
Where risk is higher, apply enhanced due diligence consistent with it: in particular, examine the background and purpose of transactions as far as reasonably possible and increase monitoring of the relationship; other measures may include more customer and beneficial owner information, source of funds and wealth, reasons for transactions, senior management approval, enhanced monitoring and a first payment through a bank account in the customer's name.
Where the risks of ML/TF/PF are higher, firms must conduct enhanced due diligence measures consistent with the risks identified. a. (a) In particular, they must: ➢ as far as reasonably possible, examine the background and purpose of the transaction; and ➢ increase the degree and…
Source wording and supporting evidenceOriginal text (excerpt)
Where the risks of ML/TF/PF are higher, firms must conduct enhanced due diligence measures consistent with the risks identified. a. (a) In particular, they must: ➢ as far as reasonably possible, examine the background and purpose of the transaction; and ➢ increase the degree and…
JMLSG Guidance Part I, Chapter 4 · JMLSG 4.64Under enhanced due diligence, firms must examine as far as reasonably possible the background and purpose of all complex or unusually…Credit institutionFinancial institution+4Obligation mapped
Plain English
Under enhanced due diligence, firms must examine as far as reasonably possible the background and purpose of all complex or unusually large transactions, unusual patterns and transactions with no apparent purpose, and increase monitoring of the relationship to spot suspicious activity. The legal duty itself is in regulation 33(1)(f) and (4) of the Money Laundering Regulations 2017.
Obligation
Where EDD measures are applied, firms must as far as reasonably possible examine the background and purpose of all complex or unusually large transactions, unusual patterns of transactions and transactions which have no apparent economic or legal purpose, and must also increase the degree and nature of monitoring of the business relationship to determine whether those transactions or that relationship appear to be suspicious.
firms must as far as reasonably possible examine the background and purpose of all complex or unusually large transactions, unusual patterns of transactions and transactions which have no apparent economic or legal purpose
Source wording and supporting evidenceOriginal text (excerpt)
Where EDD measures are applied, firms must as far as reasonably possible examine the background and purpose of all complex or unusually large transactions, unusual patterns of transactions and transactions which have no apparent economic or legal purpose. They must also increase…
JMLSG Guidance Part I, Chapter 4 · JMLSG 4.76A firm's documentation should let it show its regulator or a court how it assesses its risks, how it agrees and implements systems and…Credit institutionFinancial institution+4Obligation mapped
Plain English
A firm's documentation should let it show its regulator or a court how it assesses its risks, how it agrees and implements systems and due diligence in the light of them, how it monitors and improves them, and how it reports to senior management.
Obligation
Documentation of a firm's risk-assessment responses should enable it to demonstrate to its regulator and/or a court how it assesses ML/TF/PF threats and risks, how it agrees and implements appropriate systems and due diligence in light of the risk assessment, how it monitors and improves the effectiveness of its systems and procedures, and its arrangements for reporting to senior management on the operation of its control processes.
Documentation of those responses should enable the firm to demonstrate to its regulator and/or to a court
Source wording and supporting evidenceOriginal text (excerpt)
The responses to consideration of the issues set out above, or to similar issues, will enable the firm to tailor its policies and procedures on the prevention of money laundering and terrorist financing. Documentation of those responses should enable the firm to demonstrate to…
JMLSG Guidance Part I, Chapter 4 · JMLSG 4.77Firms should record, case by case, why they applied extra due diligence measures, or waived any, compared with their standard approach…Credit institutionFinancial institution+4Obligation mapped
Plain English
Firms should record, case by case, why they applied extra due diligence measures, or waived any, compared with their standard approach for a particular customer.
Obligation
On a case-by-case basis, firms should document the rationale for any additional due diligence measures taken (or waived) compared to the firm's standard approach, in light of its risk assessment of the particular customer.
firms should document the rationale for any additional due diligence measures it has undertaken (or any it has waived) compared to its standard approach
Source wording and supporting evidenceOriginal text (excerpt)
In addition, on a case-by-case basis, firms should document the rationale for any additional due diligence measures it has undertaken (or any it has waived) compared to its standard approach, in view of its risk assessment of a particular customer.
JMLSG Guidance Part I, Chapter 5a · JMLSG 5.1.4Firms must be able to show their supervisor that the amount of CDD and ongoing monitoring they apply is right for the money laundering…Credit institutionFinancial institution+4Obligation mapped
Plain English
Firms must be able to show their supervisor that the amount of CDD and ongoing monitoring they apply is right for the money laundering and terrorist financing risk; setting that amount by customer, relationship, product or transaction type is already covered at JMLSG 4.34. The legal duty is in regulation 28(12) and (16) of the Money Laundering Regulations 2017.
Obligation
Firms must be able to demonstrate to their supervisory authority that the extent of their CDD measures and ongoing monitoring is appropriate in view of the money laundering and terrorist financing risks.
They must be able to demonstrate to their supervisory authority that the extent of their CDD measures and monitoring is appropriate in view of the risks of money laundering and terrorist financing.
Source wording and supporting evidenceOriginal text (excerpt)
Firms must determine the extent of their CDD measures and ongoing monitoring on a risk-sensitive basis, depending on the type of customer, business relationship, product or transaction. They must be able to demonstrate to their supervisory authority that the extent of their CDD…
JMLSG Guidance Part I, Chapter 5a · JMLSG 5.1.6Where the customer or beneficial owner is a legal person, trust, company, foundation or similar arrangement (other than a company listed…Credit institutionFinancial institution+4Obligation mapped
Plain English
Where the customer or beneficial owner is a legal person, trust, company, foundation or similar arrangement (other than a company listed on a regulated market), firms must take reasonable measures to understand how it is owned and controlled. The legal duty is in regulation 28(4)(c) of the Money Laundering Regulations 2017.
Obligation
Where the customer or beneficial owner is a legal person, trust, company, foundation or similar arrangement (other than a company listed on a regulated market), firms must take reasonable measures to understand how it is owned and controlled.
firms must take reasonable measures to understand the ownership and control structure of that legal person, trust, company, foundation or legal
Source wording and supporting evidenceOriginal text (excerpt)
Where the customer or beneficial owner is a legal person (other than a company listed on a regulated market), trust, company, foundation or similar legal arrangement, firms must take reasonable measures to understand the ownership and control structure of that legal person,…
JMLSG Guidance Part I, Chapter 5a · JMLSG 5.1.9Firms must keep watch on their business relationships with customers on an ongoing basis: scrutinising transactions as the relationship…Credit institutionFinancial institution+4Obligation mapped
Plain English
Firms must keep watch on their business relationships with customers on an ongoing basis: scrutinising transactions as the relationship continues and keeping CDD information up to date. This is a separate duty from carrying out CDD measures themselves. The legal duty is in regulation 28(11) of the Money Laundering Regulations 2017.
Obligation
Firms must keep watch on their business relationships with customers on an ongoing basis: scrutinising transactions as the relationship continues and keeping CDD information up to date. This is a separate duty from carrying out CDD measures themselves.
Firms must conduct ongoing monitoring of the business relationship with their customers (section 5.7), including the scrutiny of transactions undertaken throughout the course of the relationship and keeping CDD information
Source wording and supporting evidenceOriginal text (excerpt)
Firms must conduct ongoing monitoring of the business relationship with their customers (section 5.7), including the scrutiny of transactions undertaken throughout the course of the relationship and keeping CDD information up to date. This is a separate, but related, obligation…
JMLSG Guidance Part I, Chapter 5a · JMLSG 5.2.1A firm must apply CDD measures whenever it establishes a business relationship, carries out an occasional transaction, suspects money…Credit institutionFinancial institution+4Obligation mapped
Plain English
A firm must apply CDD measures whenever it establishes a business relationship, carries out an occasional transaction, suspects money laundering or terrorist financing, or doubts the accuracy of identification documents or information it obtained earlier. The legal duty is in regulation 27(1) of the Money Laundering Regulations 2017.
Obligation
A firm must apply CDD measures whenever it establishes a business relationship, carries out an occasional transaction, suspects money laundering or terrorist financing, or doubts the accuracy of identification documents or information it obtained earlier.
A firm must apply CDD measures when it does any of the following: (a) establishes a business relationship; (b) carries out an occasional transaction
Source wording and supporting evidenceOriginal text (excerpt)
A firm must apply CDD measures when it does any of the following: (a) establishes a business relationship; (b) carries out an occasional transaction; (c) suspects money laundering or terrorist financing; or (d) doubts the veracity of documents or information previously obtained…
JMLSG Guidance Part I, Chapter 5a · JMLSG 5.2.2As a general rule, a firm must verify the identity of the customer, and of any beneficial owner, before it establishes a business…Credit institutionFinancial institution+4Obligation mapped
Plain English
As a general rule, a firm must verify the identity of the customer, and of any beneficial owner, before it establishes a business relationship or carries out a transaction, subject to the exceptions in the following paragraphs. The legal duty is in regulation 30(2) of the Money Laundering Regulations 2017.
Obligation
As a general rule, a firm must verify the identity of the customer, and of any beneficial owner, before it establishes a business relationship or carries out a transaction, subject to the exceptions in the following paragraphs.
Verify
The verification of the identity of the customer and, where applicable, the beneficial owner, must, subject to the exceptions referred to below
Source wording and supporting evidenceOriginal text (excerpt)
General rule: The verification of the identity of the customer and, where applicable, the beneficial owner, must, subject to the exceptions referred to below, take place before the establishment of a business relationship or the carrying out of a transaction.
JMLSG Guidance Part I, Chapter 5a · JMLSG 5.2.3A firm may finish verifying a customer's or beneficial owner's identity while it sets up the relationship, rather than before, only…Credit institutionFinancial institution+4Obligation mapped
Plain English
A firm may finish verifying a customer's or beneficial owner's identity while it sets up the relationship, rather than before, only where that is needed to avoid interrupting normal business and the money laundering risk is low, and it must then finish verification as soon as practicable after first contact. This reflects regulation 30(3) of the Money Laundering Regulations 2017.
Obligation
A firm that completes verification of a customer or beneficial owner during the establishment of a business relationship (only where this is necessary not to interrupt normal business and there is little ML/TF risk) must complete verification as soon as practicable after contact is first established.
Verify
provided that the verification is completed as soon as practicable after contact is first established
JMLSG Part I guidance for the UK financial sector, which the Treasury has approved; it is not law. Available only where completing verification before establishing the relationship would interrupt normal business, there is little ML/TF risk, and verification is completed as soon as practicable afterwards.
Source wording and supporting evidenceOriginal text (excerpt)
Exception if necessary not to interrupt normal business and there is little risk: In any other case, verification of the identity of the customer, and where there is one, the beneficial owner, may be completed during the establishment of a business relationship if (a) this is…
JMLSG Guidance Part I, Chapter 5a · JMLSG 5.2.4A firm may verify the identity of a customer opening an account, including a securities account, after the account is opened, but only…Credit institutionFinancial institution+4Obligation mapped
Plain English
A firm may verify the identity of a customer opening an account, including a securities account, after the account is opened, but only if it has adequate safeguards that stop any transaction by or for the customer until verification is complete. This reflects regulation 30(4) and (5) of the Money Laundering Regulations 2017.
Obligation
A firm that verifies the identity of a customer opening an account (or its beneficial owner) after the account is opened must have adequate safeguards ensuring that no transactions are carried out by or on behalf of the customer until verification is complete.
Prohibited actionVerify
provided that there are adequate safeguards in place to ensure that no transactions are carried out by or on behalf of the customer before verification has been completed
JMLSG Part I guidance for the UK financial sector, which the Treasury has approved; it is not law. Available only where adequate safeguards stop transactions being carried out before verification is complete.
Source wording and supporting evidenceOriginal text (excerpt)
Exception when opening an account: The verification of the identity of a customer (or beneficial owner, if there is one) opening an account may take place after the account (including an account which permits transactions in transferable securities) has been opened, provided…
Crown copyright. Contains public sector information licensed under the Open Government Licence v3.0 (https://www.nationalarchives.gov.uk/doc/open-government-licence/version/3/).
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Criminal Finances Act 2017 Part 3
Criminal Finances Act 2017, Part 3 (ss.44-52) - corporate offences of failure to prevent facilitation of tax evasion
UK Parliament
Text as at 1 October 2026
9 provisions accounted for · 9 independently reviewed
Crown copyright. Contains public sector information licensed under the Open Government Licence v3.0 (https://www.nationalarchives.gov.uk/doc/open-government-licence/version/3/).
CT Sanctions Regulations 2019
The Counter-Terrorism (International Sanctions) (EU Exit) Regulations 2019
HM Treasury / Secretary of State
Text as at 1 October 2026
87 provisions accounted for · 87 independently reviewed
Economic Crime and Corporate Transparency Act 2023, sections 188 to 193 (information sharing to prevent economic crime: civil liability protections) and sections 199 to 206 (failure to prevent fraud)
UK Parliament
Text as at 1 October 2026
14 provisions accounted for · 14 independently reviewed
Crown copyright. Contains public sector information licensed under the Open Government Licence v3.0 (https://www.nationalarchives.gov.uk/doc/open-government-licence/version/3/).
EMRs 2011
The Electronic Money Regulations 2011
HM Treasury
Text as at 1 October 2026
183 provisions accounted for · 183 independently reviewed
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FCA copyright material, not Crown copyright and not licensed under the Open Government Licence. The register shows a short excerpt of each paragraph with a link to the published Approach Document.
FCA SYSC financial crime
FCA Handbook: Senior Management Arrangements, Systems and Controls (SYSC) - compliance function and financial crime systems and controls (SYSC 3.2.6, 6.1, 6.3)
Financial Conduct Authority
Text as at 1 October 2026
46 provisions accounted for · 46 independently reviewed
FCA Handbook content is not covered by the Open Government Licence. Reproduced here as a short excerpt with a link to the official source; see publicTextPolicy.
FCA Financial Crime Guide content is not covered by the Open Government Licence. Reproduced here as a short excerpt with a link to the official source; see publicTextPolicy.
FCG chapters 4-8 and Annex 1
FCA Financial Crime Guide (FCG), chapters 4-8 and Annex 1 (fraud, data security, bribery and corruption, sanctions and proliferation financing, insider dealing and market manipulation; common terms)
Financial Conduct Authority
Text as at 1 October 2026
74 provisions accounted for · 74 independently reviewed
Regulation (EU) 2015/847 of the European Parliament and of the Council of 20 May 2015 on information accompanying transfers of funds and repealing Regulation (EC) No 1781/2006, as it forms part of UK domestic law
HM Treasury
Text as at 30 June 2026
27 provisions accounted for · 27 independently reviewed
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Iran Nuclear Regulations 2019
The Iran (Sanctions) (Nuclear) (EU Exit) Regulations 2019
HM Treasury / Secretary of State
Text as at 1 October 2026
122 provisions accounted for · 122 independently reviewed
JMLSG copyright material, not Crown copyright and not licensed under the Open Government Licence. The register shows a short excerpt of each paragraph with a link to the published Guidance.
JMLSG Guidance Part I, Chapter 2
JMLSG Guidance Part I: Prevention of money laundering / combating terrorist financing, Chapter 2 (Internal controls)
Joint Money Laundering Steering Group
2023 revised version, updated August 2025
24 provisions accounted for · 24 independently reviewed
JMLSG copyright material, not Crown copyright and not licensed under the Open Government Licence. The register shows a short excerpt of each paragraph with a link to the published Guidance.
JMLSG Guidance Part I, Chapter 3
JMLSG Guidance Part I: Prevention of money laundering / combating terrorist financing, Chapter 3 (Nominated officer/MLRO)
Joint Money Laundering Steering Group
2023 revised version, updated August 2025
49 provisions accounted for · 49 independently reviewed
JMLSG copyright material, not Crown copyright and not licensed under the Open Government Licence. The register shows a short excerpt of each paragraph with a link to the published Guidance.
JMLSG Guidance Part I, Chapter 4
JMLSG Guidance Part I: Prevention of money laundering / combating terrorist financing, Chapter 4 (Risk-based approach)
Joint Money Laundering Steering Group
2023 revised version, updated August 2025
83 provisions accounted for · 83 independently reviewed
JMLSG copyright material, not Crown copyright and not licensed under the Open Government Licence. The register shows a short excerpt of each paragraph with a link to the published Guidance.
JMLSG Guidance Part I, Chapter 5a
JMLSG Guidance Part I: Prevention of money laundering / combating terrorist financing, Chapter 5 (Customer due diligence), part a
Joint Money Laundering Steering Group
2023 revised version, updated August 2025
119 provisions accounted for · 119 independently reviewed
JMLSG copyright material, not Crown copyright and not licensed under the Open Government Licence. The register shows a short excerpt of each paragraph with a link to the published Guidance.
MLR 2017
The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017
HM Treasury
Text as at 30 June 2026
311 provisions accounted for · 311 independently reviewed
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SI 2026/621
The Money Laundering and Terrorist Financing (Amendment) Regulations 2026
HM Treasury
Text as at 21 July 2026
39 provisions accounted for · 39 independently reviewed
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POCA 2002 Part 7
Proceeds of Crime Act 2002, Part 7 (Money Laundering), sections 327 to 340, with Schedule 9 (Regulated Sector and Supervisory Authorities)
UK Parliament / Home Office
Text as at 30 June 2026
41 provisions accounted for · 41 independently reviewed
Crown copyright. Contains public sector information licensed under the Open Government Licence v3.0 (https://www.nationalarchives.gov.uk/doc/open-government-licence/version/3/).
POCA 2002 Part 8
Proceeds of Crime Act 2002, Part 8 (Investigations), Chapters 1, 2 and 4 - England and Wales and Northern Ireland: production, disclosure, customer information and account monitoring orders, search and seizure warrants, and unexplained wealth orders (ss.341-379, 412A-416)
UK Parliament
Text as at 1 October 2026
76 provisions accounted for · 76 independently reviewed
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PSRs 2017
The Payment Services Regulations 2017
HM Treasury
Text as at 1 October 2026
262 provisions accounted for · 262 independently reviewed
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Russia Regulations 2019
The Russia (Sanctions) (EU Exit) Regulations 2019
HM Treasury / Secretary of State
Text as at 1 October 2026
622 provisions accounted for · 622 independently reviewed
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SAMLA 2018
Sanctions and Anti-Money Laundering Act 2018
UK Parliament / HM Treasury / Secretary of State
Text as at 1 October 2026
140 provisions accounted for · 140 independently reviewed
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Terrorism Act 2000 Part III
Terrorism Act 2000, Part III (Terrorist Property), sections 14 to 31 (including 17A, 21ZA to 21ZC and 21A to 21H)
UK Parliament / Home Office
Text as at 30 June 2026
44 provisions accounted for · 44 independently reviewed
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Terrorism Act 2000 Schedules 6 and 6A
Terrorism Act 2000, Schedules 6 and 6A - financial information orders and account monitoring orders
UK Parliament
Text as at 1 October 2026
16 provisions accounted for · 16 independently reviewed
Crown copyright. Contains public sector information licensed under the Open Government Licence v3.0 (https://www.nationalarchives.gov.uk/doc/open-government-licence/version/3/).
Belarus Sanctions Regulations 2019264 provisions
The Republic of Belarus (Sanctions) (EU Exit) Regulations 2019
Crown copyright. Contains public sector information licensed under the Open Government Licence v3.0 (https://www.nationalarchives.gov.uk/doc/open-government-licence/version/3/).
Crown copyright. Contains public sector information licensed under the Open Government Licence v3.0 (https://www.nationalarchives.gov.uk/doc/open-government-licence/version/3/).
Criminal Finances Act 2017 Part 39 provisions
Criminal Finances Act 2017, Part 3 (ss.44-52) - corporate offences of failure to prevent facilitation of tax evasion
Crown copyright. Contains public sector information licensed under the Open Government Licence v3.0 (https://www.nationalarchives.gov.uk/doc/open-government-licence/version/3/).
CT Sanctions Regulations 201987 provisions
The Counter-Terrorism (International Sanctions) (EU Exit) Regulations 2019
Economic Crime and Corporate Transparency Act 2023, sections 188 to 193 (information sharing to prevent economic crime: civil liability protections) and sections 199 to 206 (failure to prevent fraud)
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FCA copyright material, not Crown copyright and not licensed under the Open Government Licence. The register shows a short excerpt of each paragraph with a link to the published Approach Document.
FCA SYSC financial crime46 provisions
FCA Handbook: Senior Management Arrangements, Systems and Controls (SYSC) - compliance function and financial crime systems and controls (SYSC 3.2.6, 6.1, 6.3)
FCA Handbook content is not covered by the Open Government Licence. Reproduced here as a short excerpt with a link to the official source; see publicTextPolicy.
FCA Financial Crime Guide content is not covered by the Open Government Licence. Reproduced here as a short excerpt with a link to the official source; see publicTextPolicy.
FCG chapters 4-8 and Annex 174 provisions
FCA Financial Crime Guide (FCG), chapters 4-8 and Annex 1 (fraud, data security, bribery and corruption, sanctions and proliferation financing, insider dealing and market manipulation; common terms)
Regulation (EU) 2015/847 of the European Parliament and of the Council of 20 May 2015 on information accompanying transfers of funds and repealing Regulation (EC) No 1781/2006, as it forms part of UK domestic law
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Iran Nuclear Regulations 2019122 provisions
The Iran (Sanctions) (Nuclear) (EU Exit) Regulations 2019
JMLSG copyright material, not Crown copyright and not licensed under the Open Government Licence. The register shows a short excerpt of each paragraph with a link to the published Guidance.
JMLSG Guidance Part I, Chapter 224 provisions
JMLSG Guidance Part I: Prevention of money laundering / combating terrorist financing, Chapter 2 (Internal controls)
JMLSG copyright material, not Crown copyright and not licensed under the Open Government Licence. The register shows a short excerpt of each paragraph with a link to the published Guidance.
JMLSG Guidance Part I, Chapter 349 provisions
JMLSG Guidance Part I: Prevention of money laundering / combating terrorist financing, Chapter 3 (Nominated officer/MLRO)
JMLSG copyright material, not Crown copyright and not licensed under the Open Government Licence. The register shows a short excerpt of each paragraph with a link to the published Guidance.
JMLSG Guidance Part I, Chapter 483 provisions
JMLSG Guidance Part I: Prevention of money laundering / combating terrorist financing, Chapter 4 (Risk-based approach)
JMLSG copyright material, not Crown copyright and not licensed under the Open Government Licence. The register shows a short excerpt of each paragraph with a link to the published Guidance.
JMLSG Guidance Part I, Chapter 5a119 provisions
JMLSG Guidance Part I: Prevention of money laundering / combating terrorist financing, Chapter 5 (Customer due diligence), part a
JMLSG copyright material, not Crown copyright and not licensed under the Open Government Licence. The register shows a short excerpt of each paragraph with a link to the published Guidance.
MLR 2017311 provisions
The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017
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SI 2026/62139 provisions
The Money Laundering and Terrorist Financing (Amendment) Regulations 2026
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POCA 2002 Part 741 provisions
Proceeds of Crime Act 2002, Part 7 (Money Laundering), sections 327 to 340, with Schedule 9 (Regulated Sector and Supervisory Authorities)
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POCA 2002 Part 876 provisions
Proceeds of Crime Act 2002, Part 8 (Investigations), Chapters 1, 2 and 4 - England and Wales and Northern Ireland: production, disclosure, customer information and account monitoring orders, search and seizure warrants, and unexplained wealth orders (ss.341-379, 412A-416)
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Crown copyright. Contains public sector information licensed under the Open Government Licence v3.0 (https://www.nationalarchives.gov.uk/doc/open-government-licence/version/3/).
Crown copyright. Contains public sector information licensed under the Open Government Licence v3.0 (https://www.nationalarchives.gov.uk/doc/open-government-licence/version/3/).
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Terrorism Act 2000 Part III44 provisions
Terrorism Act 2000, Part III (Terrorist Property), sections 14 to 31 (including 17A, 21ZA to 21ZC and 21A to 21H)
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Terrorism Act 2000 Schedules 6 and 6A16 provisions
Terrorism Act 2000, Schedules 6 and 6A - financial information orders and account monitoring orders
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