This addendum contains legislative updates and shows a change in LSAG’s position and expectations. The areas covered include:
- Economic Crime Levy considerations for larger firms
- Discrepancy Reporting Guidance
- Registers of Overseas Entities update
- Changes brought in by the Economic Crime Act, including a new POCA de minimis limit of £1,000
- A definition of Supply Chain Risk, which is particularly relevant in the context of financial sanctions requirements
- Supervisory expectations in respect of evidencing Third-Party Source of Funds involved in a transaction
- LSAG-proposed amends to the Identification & Verification approach set out in existing LSAG guidance
- Erratum: Beneficial Ownership thresholds.