Compliance Monitor
To boldly go…back
Timon Molloy, Editor
On the ides of July the six major UK banks announced that they would embark on a major voyage, hopefully it will not be into
the unknown. They chose the occasion of the Financial Services Authority’s major money laundering conference in London to
reveal plans, developed under the regulator’s watchful gaze, for a comprehensive retrospective Know Your Customer (KYC) exercise.
The aim is to ensure that they have reconfirmed the identities of all existing clients, including those taken on prior to
1 April 1994 when the Money Laundering Regulations 1993 that mandate KYC checks came into force. In the accompanying “Statement
of Principles for fighting crime and the financing of terrorism”, Abbey National, Barclays, HBOS, HSBC, LloydsTSB and The
Royal Bank of Scotland Group note that the initiative “goes well beyond what is required by UK law.”This is true but they
may not have stolen too long a march on the Financial Action Task Force. In its consultation paper on the review of the Forty
Recommendations that was issued at the end of May, the FATF raises the possibility of requiring confirmation of identity for
all customers.