The new JMLSG guidelines are underpinned by two major themes – that Executive Management will be held accountable for counter money laundering and terrorist financing measures, and that the measures should be risk-based. By “risk-based,” the guidelines indicate that the actions and resources put in place should be proportionate to the risk, based upon the nature of the client, transaction, and channel. Both the JMLSG and the FSA (in their recent letter to the JMLSG Chairman) recognise that, for the majority of counter money laundering and terrorist financing activities, a “zero-defect” approach is neither viable, nor conducive to good practice. However, when it comes to Sanctions List Compliance, although Executive Management are still accountable, a risk-based approach is not acceptable. |