JMLSG has noted the parts of its guidance affected by Brexit. In particular:
- EEA countries are now third countries;
- the same level of information is to be provided by UK PSPs regardless of whether funds are being transferred to or from EEA or other third countries;
- references to complying with ESA guidelines are no longer appropriate; and
- firms generally need to consider the effectiveness of any country’s regime when determining what level of EDD to apply to respondents in that country.