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Introduction

All businesses that are covered by the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 have to put in place suitable anti-money laundering controls. These regulations were strengthened with effect from 10 January 2020 by SI 2019/1511, which implemented the fifth EU Anti-Money Laundering Directive and placed a further emphasis on customer due diligence and sought to improve transparency of information on the ownership of companies and trusts. Further changes were made from 30 December 2020 by SI 2020/991 to clarify the 2019 amendments, including what constitutes a ‘reliable source which is independent of the person whose identity is being verified’ for the purposes of SI 2017/692, reg 28(19). While EEA countries no longer hold a specified status for the money laundering regulations post-Brexit, these countries are not considered to be ‘high risk’ and, consequently, the practical requirements of the regulatory regime remain relatively unchanged.

The key requirements of