On 10 November, FATF published addition guidance, saying that in October 2021, it adopted minor amendments to Recommendation 23 and the FATF Glossary to clarify how the existing requirements in Recommendation 18 (Internal controls and foreign branches and subsidiaries) to implement group-wide programmes against money laundering and terrorist financing apply to DNFBP under Recommendation 23.  These Explanatory Materials in the guidance give more clarity as to the FATF intentions in this area and how they fit with its overall objective of improving the effectiveness of AML/CFT measures.  They explain the basic concepts, and answer questions such as ‘What does the FATF mean by common ownership, management or compliance control?’ and ‘How should DNFBP groups and other structures implement group-wide programmes?’


Any modest contributions for my time and ongoing expenses are welcomed!  I have a page where you can do so, and where one-off contributions start as low as $3, at https://www.buymea3coffee.com/KoIvM842y

Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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