Raise the bar [2]: EBA revised Guidelines on ML/TF risk factors – Customer Due Diligence

Denis O’Connor, aFellow of both the Institute of Chartered Accountants in England & Walesand the Chartered Institute of Securities and Investment, was a member of theBritish Bankers’ Association Money Laundering Committee from 2003-10 and amember of the Joint Money Laundering Steering Group’s Board and Editorial Panelbetween 2010 and 2016. He has been a frequent speaker at industry conferenceson financial crime issues, both in the UK and abroad.

The European Banking Authority (EBA)recently proposed changes to its Guidelines [1] on money laundering/terroristfinancing (ML/TF) risk factors, in light of the latest EU legislation and theemergence of new risks and weaknesses identified in the EBA’s implementationreview. [2] In the second of two articles [3], Denis O’Connor looks atGuideline 4 on customer due diligence (CDD). Since the Guidelines are addressedto all banks operating in the EU, he says financial crime staff in theseinstitutions would well advised to review the latest draft and consider howtheir own firm’s systems and controls might be enhanced.