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

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...