In August, HMRC reminded supervised entities that Turkey and Jamaica had been removed from the grey list in June. However, they neglected to mention that Monaco and Venezuela had been added—or “recognised” in the wording of FATF.

As a general rule -

Money Service Businesses are viewed as high risk. Money Service Businesses do not do enough SAR. When in doubt - report.

Anyone in the business who feels something is off should report that to the Nominated Officer. I firmly recommend that these internal reports should NOT be called SAR. (I’ll explain later). Staff should be encouraged to report whenever they feel the slightest bit suspicious.

In practical terms - PEP detection needs to be part of your risk-based approach. You might for example ask the question over a certain limit, or if the transaction is unusual in another way.

If your business is presented with a PEP, you must conduct Enhanced Due Diligence. Essentially, you need to satisfy yourself that the person in front of you is not attempting to transact with the proceeds of abuse of a public office.

Customer Due Diligence

This is the grown-up version of Know Your Customer (KYC).

It's not an only-child. there's big sister Enhanced Due Diligence (EDD) and baby brother Simplified Due Diligence (SDD) too. We'll get to them later.

Whether you need a compliance officer, depends on the size and complexity of your business. The compliance officer is responsible for ensuring the business is compliant with the Regulations. This might be an existing officer, taking on more responsibility, or it may be a new position. However - the person should be a director or equivalent or senior manager.

These procedures should not be aspirational - they should be actual. Most sanctions and penalties are levied not because a procedure is wrong, but because a firm does not follow its own procedure, or has no procedure at all.