The aim is to provide subject persons with more guidance in order to better carry out their AML/CFT obligations.
The salient points
- Chapter 3 of the Implementing Procedures Part I provides subject persons with a better understanding of what the Risk Based Approach entails, and lays down detailed guidance on the carrying out of business risk assessments and customer risk assessments.
- Chapter 4 lays out the various Customer Due Diligence obligations, including guidance in circumstances where subject persons are faced with high-risk scenarios. Moreover, new technological alternatives are offered to fulfil AML/CFT obligations.
- Chapter 6 of the revised procedures focuses on the outsourcing arrangements in the ambit of such obligations.
- Chapter 8 delves into the definition of non-reputable jurisdictions and identifying high-risk jurisdictions
- A new section (4.11) in Implementing Procedures Part I, emphasises the aspect of sanctions screening, freezing of assets and reporting obligations.
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The 4th AML Directive brought with it a mandatory risk-based approach, whereby subject persons must draw up AML/CFT policies and procedures commensurate to their risk appetite and to the risks that they are exposed to.