Amendments to MLRs
The UK Government recently called for views on a number of proposed amendments to the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 Statutory Instrument 2022.
The proposals focus on strengthening the UK’s anti-money laundering regime in order to maintain international standards, whilst ensuring clarity on a number of practical matters such as the scope of the Money Laundering Regulations and the enhancement of supervisory powers.
Propertymark’s response highlights the importance of a consistent approach to anti-money laundering to minimise opportunities for those engaging in money laundering (ML) or terrorist financing (TF) to exploit. Our submission supports proposals to enable Suspicious Activity Reports (SARs) to be accessed by supervisory authorities, enabling a supervisor to build up a comprehensive understanding of the ML and TF risks within its sector.
We also agree with the amendment to the definition of an Art Market Participant (AMP) and caution that digital art should also be brought within its scope. The consultation also considers the AML obligations of Trust or Company Service Providers (TCSPs) and the treatment of cryptoassets.
Read our response
Supervisory bodies
Propertymark recently responded to the UK Government’s call for evidence on its Review of the UK’s AML/CFT Regulatory and Supervisory Regime. The consultation sought views on whether, following the UK’s departure from the European Union, the anti-money laundering and counter-terrorist financing regulations are as effective as possible in preventing such activity, and focused on whether certain regulations are operating as intended.
Our response recommends a consolidation of the number of Professional Body Supervisors in order to improve overall performance and suggests that a focus on sector-specific supervisors would help to reduce the amount of conflicting guidance issued.
We also continue our call for a public register of overseas owners – the need for which was most recently emphasised by the Pandora Papers scandal – and a reduction in the current EUR10,000 lettings threshold to a nil limit to close the potential loophole that exists.
