About a-team Marketing Services
The knowledge platform for the financial technology industry
The knowledge platform for the financial technology industry

A-Team Insight Blogs

IMS Responds to Government’s Money Laundering Consultation

Subscribe to our newsletter

The IMS Group (IMS), the compliance and regulation consultant, has today responded to the Government’s consultation on reviewing Money Laundering Regulations 2007. The consultation period closes on 30 August 2011.

The Government’s proposals are intended to give businesses greater confidence to focus compliance on their highest risk areas and to discourage the tick-box approach taken by some businesses.

Peter Moore, head of regulation & compliance at IMS, says: “One aspect of the review looks at de-criminalising procedural failings. Currently there are criminal sanctions for those who do not have the appropriate systems and controls to combat money laundering. However, offences have not been widely prosecuted. We believe that the legal and regulatory requirements that empower and encourage firms to achieve a prescribed objective, rather than make them fearful of not doing so, are more likely to succeed. We therefore support proposals to decriminalise certain criminal offences in the Money Laundering Regulations.

“It was a shame to see that the Consultation did not cover staff training. Many firms engage with service providers for anti-money laundering training, with much being a computer-based approach. This periodic anti-money laundering technique can, on occasions, represent tick-box compliance at its worse, making it ineffective. We hope to see this addressed going forward.

“Much has been made in the Consultation of the perceived failure of firms relying on checks performed by other firms. It stresses that these provisions are there to simplify the obligations on the customer and firms party to a transaction. This should be reconciled with the FSA’s approach who, in addition, advocates that firms employ sample testing on other firms. We encourage HM Treasury to engage with the FSA to clarify this point.

“Regulatory responsibility will always fall back to an individual firm, whether or not they have relied on another regulated firm. Therefore, it is in that firm’s interests to perform customer due diligence themselves rather than rely on the assurance of another firm. We believe that a true risk-based approach should allow a firm to determine what risk is faced by reliance on another firm.”

Subscribe to our newsletter

Related content

WEBINAR

Upcoming Webinar: Hearing from the Experts: AI Governance Best Practices

9 September 2025 10:00am ET | 3:00pm London | 4:00pm CET Duration: 50 Minutes The rapid spread of artificial intelligence in the financial industry presents data teams with novel challenges. AI’s ability to harvest and utilize vast amounts of data has raised concerns about the privacy and security of sensitive proprietary data and the ethical...

BLOG

EU’s AI Act Loads Data Responsibilities on Institutions but also Offers Opportunities

Financial institutions are under pressure to put their data estates in order as the European Union’s artificial intelligence regulation comes into force this week, threatening huge fines for failures to observe its tough rules on the safe and fair use of the technology. Nevertheless, the introduction of stringent measures that will place new compliance burdens...

EVENT

TradingTech Briefing New York

Our TradingTech Briefing in New York is aimed at senior-level decision makers in trading technology, electronic execution, trading architecture and offers a day packed with insight from practitioners and from innovative suppliers happy to share their experiences in dealing with the enterprise challenges facing our marketplace.

GUIDE

AI in Capital Markets: Practical Insight for a Transforming Industry – Free Handbook

AI is no longer on the horizon – it’s embedded in the infrastructure of modern capital markets. But separating real impact from inflated promises requires a grounded, practical understanding. The AI in Capital Markets Handbook 2025 provides exactly that. Designed for data-driven professionals across the trade life-cycle, compliance, infrastructure, and strategy, this handbook goes beyond...