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RMs' Anti-Money Laundering Duties In The UK

Chris Hamblin, Editor, Offshore Red, 16 July 2013

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Relationship managers in certain countries are reportedly being held to greater account than before for their compliance duties; here is a list of them as laid out in the wealth management chapter of the Joint Money Laundering Steering Group's guidelines.

The JMLSG starts by enumerating the money laundering risks in the sector. All relationship managers ought to be aware of them, even though their compliance departments typically have the job of codifying them in company policy. They are as follows.

  • The combination of wealth and power in the same people. Those two things go hand-in-hand in many countries, which is why the Financial Action Task Force reckons “policially exposed persons” to be risky customers at all times. If they have recently wielded political power, they may have used it to accumulate the wealth that the RM is onboarding.
  • Many accounts with other wealth management firms. If the customer does not tell the RM about these, it may be difficult for the financial firm to build up an accurate picture of his worldwide dealings, as required by the Money Laundering Regulations 2007. Regulation 5(c) obliges the firm (in the shape of the RM, usually) to obtain information on the purpose and intended nature of the business relationship. Regulation 8(2)(a) calls for “ongoing monitoring of a business relationship.” This entails scrutiny of transactions undertaken throughout the course of the individual's relationship with the bank (including, where necessary, his source of funds which the bank must in any case establish at the beginning of its dealings with him) to ensure that the transactions are consistent with the RM's knowledge of the customer, his business and risk profile.
  • The tendency of customers to want their services to be conducted discreetly and in confidence. This seems to be a slight misunderstanding of the word “confidentiality,” which in general global governmental parlance merely refers to information about an individual being shielded from the gaze of other individuals and not from the government, whose informant the RM is on this subject. Only the words “privacy” or “secrecy” denote account information being shielded from the gaze of the government as well as from that of fellow-citizens.
  • The existence of the offshore world. The word that the JMLSG uses here is “concealment.” To it, there is no difference between the concealment of something and “the misuse of services such as offshore trusts and...shell companies.”

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