The JMLSG is consulting on changes to chapter 18 in Part II of its guidance, for wholesale markets. The changes generally update references, and:
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clarify that as market abuse is a predicate offence, settlement of certain trades could represent placement for money laundering purposes;
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include a new section on CDD in relation to authorised personnel acting on behalf of a customer;
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note the importance of sanctions checks and appropriate OFSI reports in relation to securities, which are lower risk for AML purposes;
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highlight the dangers of tax evasion risks of structuring bespoke cross-border transactions in a way that constitutes dividend arbitrage; and
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add a section on wholesale subscription finance in private capital funds.
Consultation closes on 1 July.