MLR1PP7310 - Penalties Guidance: Other related breaches

  1. Other customer due diligence measures:

Regulation 9 - failure to comply with the requirements on timing of verification of identity of clients and any beneficial owner(s)

Regulation 11 - continuing with transaction/business relationship where unable to apply customer due diligence measures

  1. Registration breaches:
    • Breaches of Regulation 26, 27(4) and 33 (registration breaches) are subject to a modified penalty framework. This is fully explained in Section 7.2 of this guidance.
  1. Other breaches:
    • Regulation 21 - failure to take appropriate measures to provide the required training
    • Regulation 18 - failing to follow a direction made by H M Treasury under this regulation (directions where FATF applies counter-measures). If FATF have decided to apply counter-measures to a specific individual they will be included on the H M Treasury Sanctions List. A breach of this regulation could be highly indicative of involvement in money laundering.