Amendments to the Money Laundering, Terrorist Financing and Transfer of Funds: RPC Opinion
Regulatory Policy Committee policy opinion on HMT's amendments to the Money Laundering, Terrorist Financing and Transfer of Funds
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皇冠体育app proposed regulations amend the current Money Laundering Regulations (MLRs) to ensure that they remain effective and proportionate, and that the UK remains compliant with international standards.
皇冠体育app RPC considers the impact assessment to be not fit for purpose. 皇冠体育app department has not sufficiently addressed the concerns raised in the RPC鈥檚 initial review notice. 皇冠体育app IA has not provided a proportionate assessment of direct impacts to businesses nor robust justification for non-monetised impacts. 皇冠体育app IA has not considered whether small and micro businesses (SMBs) could be disproportionately impacted by the proposal. 皇冠体育apprefore, the RPC is unable to validate the EANDCB and does not consider the IA as fit for purpose.聽
皇冠体育app RPC also finds weaknesses in the IA鈥檚 consideration of the cost benefit analysis in that the department must provide further details on the data limitations and consider the use of previous MLR IAs or proxies to inform the cost estimates. It is unclear how the department has used the consultation to fill evidence gaps and improve the robustness of the EANDCB estimate. 皇冠体育appre are also weaknesses identified by the RPC in relation to wider impacts, specifically the IA should provide stronger evidence to support this claim and a more comprehensive assessment of impacts on innovation, trade, and competition.
皇冠体育app RPC publishes its opinion to assist parliamentary scrutiny of the bill.
皇冠体育app IA and associated documents can be found