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Volume 3, Edition 1                     Chatterbox                          07/04/2020







         Part Two: Regulatory Response                                                In Focus: FATF



                                                                                     Plenary Round Up
                                                                                       (February 2020)
        United Kingdom


                                                                                  High-risk jurisdictions subject to
                                                                                          a call for action
                                                                                      High-risk jurisdictions have
                                                                                    significant strategic deficiencies
                                                                                   in their regimes to counter money
                                                                                   laundering, terrorist financing, and
                                                                                       financing of proliferation.
                                                                                     The FATF calls on all members
        Proposal for a levy to tackle financial   markets, property sector and financial   and urges all jurisdictions to
        crime                               services. It is hoped that the ECL will   apply enhanced due diligence,
                                            generate much needed resources           and in the most serious cases,
        Plans are afoot for a new Economic   for law enforcement to invest in      countries are called upon to apply
        Crime Levy (ECL) to be introduced   new technologies and more financial     counter-measures to protect the
        to raise money to support the fight   investigators to help turn the tide.  international financial system from
                                                                                    the ongoing money laundering,
        against crime and dirty money.      A consultation on this levy is expected   terrorist financing, and proliferation
        It is well-known that the UK, London   during 2020 with the levy coming into   financing (ML/TF/PF) risks
        in particular, is susceptible to washing   force 2022/3.                     emanating from the country.
        the proceeds of international crime                                        This list is often externally referred
        and acts as a magnet and haven to   https://www.reuters.com/article/        to as the “black list” and includes
        corrupt foreign money.              us-britain-budget-levy/uk-plans-levy-   Democratic People’s Republic of
        There are no reliable estimates,    on-banks-and-others-to-help-tackle-        Korea (DPRK) and Iran.
        but it is suspected that significantly   money-laundering-idUSKBN20U0ZE
        more than £100 billion a year is                                           Jurisdictions under Increased
        being laundered through the capital                                                Monitoring
                                                                                   (previously called Improving Global
                                                                                    AML/CFT Compliance: On-going
        FCA Supervision Reports and Updates                                                  process)
                                                                                   The list includes countries that are
                                                                                   actively working with the FATF to
                                                                                    address strategic deficiencies in
                                                                                    their regimes to counter money
                                                                                   laundering, terrorist financing, and
                                                                                        proliferation financing.
                                                                                   This list is often externally referred
                                                                                    to as the ‘grey list’ and now has
                                                                                  eighteen jurisdictions listed including
        Sector Views: AI & Big Data         consumers in some insurance and                  Iceland!
                                            affordable credit products.  The
        The FCA currently has its eye on Big   groups likely most affected would be   https://www.fatf-gafi.org/publications/
        Data and AI and how firms use data.    the more vulnerable or lower income   high-risk-and-other-monitored-jur
        A key area of concern is unfair pricing   groups.                           isdictions/?hf=10&b=0&s=desc(fa
        for insurance and credit products.                                                 tf_releasedate)
                                            Unethical use of data can also create
        Firms’ have the ability to personalise   new forms of unfair pricing or
        pricing and there is concern that   algorithmic bias, and could exclude
        reduced risk pooling could lead     vulnerable consumers...
        to financial exclusion for some




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