On 11 March, HM Treasury published a consultation entitled “Improving the Effectiveness of the Money Laundering Regulations”. The consultation follows the 2022 government review of the anti-money laundering/ counter-terrorist financing (AML/CTF) regulatory and supervisory regime and its Economic Crime Plan set for 2023-26. The overarching aim is to improve the effectiveness of the current Money Laundering Regulations 2017 (MLRs).
Reducing money laundering is one of the core goals of the Economic Crime Plan, and this consultation and any amendments to the MLRs that may flow are perhaps a small step towards achieving that. For regulated firms seeking to ensure compliance with the MLRs on a day to day basis, however, any improvements, clarifications and simplifications will be welcome.
The consultation focuses on areas of the MLRs where additional clarity might support compliance or where there might be opportunities for stakeholders to work together in a better way, with an emphasis on proportionality. With the UK government increasingly placing the burden on the private sector as the first line of defence against financial crime – as seen most recently in the new corporate criminal offence of failure to prevent fraud – the need for proportionality, in particular, is stark.
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