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

Recorded Webinar: Streamlining trading and investment processes with data standards and identifiers

Financial institutions are integrating not only greater volumes of data for use across their organisation but also more varieties of data. As well, that data is being applied to more use cases than ever before, especially regulatory compliance and ESG integration. Due to this increased complexity of institutions’ data needs, however, information often arrives into...

BLOG

A-Team Group Data Management Awards USA Winners Announced at DMS NYC 2025

A-Team Group has announced the winners of its 4th annual Data Management Insight Awards USA 2025, and we extend our congratulations to the individuals and companies recognised with awards this year. The event shines a light on the top providers of data management solutions, services, and consultancy for the capital markets across the United States....

EVENT

Data Management Summit London

Now in its 16th year, the Data Management Summit (DMS) in London brings together the European capital markets enterprise data management community, to explore how data strategy is evolving to drive business outcomes and speed to market in changing times.

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...