JMLSG updates Part I AML Guidance, clarifying CDD requirements for bank insolvencies, customers acting on behalf of others and pooled client a/cs, including “unusually” large or complex transactions

by | Sep 3, 2026

The revisions affect paragraphs 2.9, 5.2.4A, 5.3.94A, 5.3.99 and 5.3.142 and Annex 5-V, and have been submitted to HM Treasury for Ministerial approval. The amendments cover the interpretation of “unusually” complex or large transactions, an exception relating to bank...

JMLSG consults on proposed updates to Part I of its AML/CFT Guidance, including changes to unusual transactions, bank insolvency exceptions and pooled client accounts – feedback until 29 June 2026

by | Jun 1, 2026

The consultation proposes revisions to Part I of the JMLSG Guidance, including clarification of “unusually” complex, large or patterned transactions, a new exception for opening accounts for UK insolvent bank customers, and revised treatment of pooled client accounts....