6. Working with partners at home and overseas
We engaged throughout 2015/16 with other EU banking supervisors through the AML Committee of the joint European Supervisory Authorities (ESAs). Our contribution included co-chairing a group drafting guidelines on simplified and enhanced customer due diligence, and on the factors that credit and financial institutions should consider when assessing the money laundering and terrorist financing risk associated with individual business relationships and occasional transactions. In October 2015 the ESAs published two sets of draft guidelines for consultation, one on risk factors and a second on the risk-based approach to supervision. We expect the final guidelines to be published later this year. A joint opinion on applying customer due diligence measures to customers who are asylum seekers from higher-risk third countries and territories was published in April 2016.
Joint Money Laundering Intelligence taskforce (JMLIT)
Since April 2014 we have played a key role in establishing a mechanism for improved information-sharing between financial institutions and law enforcement organisations.
Working in collaboration with the Home Office and the Bank of England, plus a range of banks and other organisations, we helped to develop the JMLIT, originally a pilot project and now a permanent taskforce. Its aim is to improve intelligence-sharing arrangements to help fight money laundering and financial crime. The JMLIT consists of three tiers – an operational group, a strategic group and a financial crime alerts service. The FCA attends the management board and strategic group and engages with the Financial Sector Forum, the group that drives this initiative.
Although the emphasis of the group is on making the UK a more difficult place to launder the proceeds of crime, discussions have also focused on improved information sharing covering terrorist financing. Following the steer of the JMLIT Management Board, we have presented to overseas regulators on the JMLIT’s purpose, briefing key economic crime overseas partners, including Italian, US, Hong Kong and UAE authorities.
We also hosted a JMLIT briefing for small banks and building societies with the aim of encouraging participation from a broader range of institutions in the regulated sector.