JMLSG has published updates to its guidance in respect of asset finance and syndicated lending. The guidance:
- in respect of asset finance, describes the main types of asset finance and discussed when its provision involves regulated activities for the purposes of FSMA. It then sets out key features that can decrease or increase money laundering risk and suggests areas for specific risk assessment;
- in respect of syndicated lending, explains the structure of syndicated loans, the roles of the parties and looks at both primary and secondary markets. It looks at who the customer is (and who is not a customer) for AML purposes and gives guidance on monitoring of risks and the risks of transacting with specific types of third party.