Framework Agreements: the customer contract model for technology service providers
As part of the Government’s strategy to ramp up the fight against money laundering, a new Office of Professional Body Anti-Money Laundering Supervision (OPBAS) will be introduced in 2018. This follows the introduction of the Money Laundering Regulations 2017 (see our related blog) on 26 June 2017.
The Government has charged the FCA with reviewing the quality of AML supervision with a view to driving up standards and ensuring quality and consistency across all professional body supervisors. Further to its proposals earlier in the year (see our related blog) the Government has published draft Regulations that will give powers and responsibilities to OPBAS.
A full list of those bodies falling within the scope of the OPBAS is here and includes those for legal and accountancy services.
In turn the FCA has issued a consultation on the OPBAS published on 24 July. This consultation proposes text for a specialist sourcebook for professional body supervisors that sets out expectations in relation to anti-money laundering supervision.
In presenting the consultation the FCA confirmed that the OPBAS’s approach will be to:
The OPBAS will be funded via a levy on the professional bodies.
The emphasis on a risk-based approach is core to the new regime under the Money Laundering Regulations 2017 and the EU Fourth Money Laundering Directive which it implements into national law. Expectations are put on supervisory authorities as well as those that they regulate.
The FCA’s consultation can be found here, and views can be submitted until 23 October 2017.
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