Emma RadmoreJMSLG has confirmed the changes to its Part II guidance on Trade Finance (although the changes remain subject to Treasury approval), and is consulting on changes to Chapter 5.7 in Part I of its guidance. The changes look to stress the need for monitoring of customer activity to take place on a risk-based basis, and emphasises that transaction monitoring is a dynamic process such that monitoring arrangements should be regularly reviewed. It notes that this may result in firms allocating resources away from, for example, arrangements that seldom contribute to management of financial crime risk. A further addition notes that firms need an appropriate governance mechanism for oversight, review and approval of monitoring processes and parameters, including documenting procedures and rationale.
Comments are due by 30 October.
