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 insolvencies, pooled client accounts and provisions for customers acting on behalf of others…