Recent Events in the Middle East
Further to the recent instability in the Middle East, CTAs subject to the Anti-Money Laundering Regulations 2007 with clients in affected areas should review their arrangements for dealing with PEPs (Politically Exposed Persons), their use of due diligence and other obligations under the Proceeds of Crime Act 2002. It is particularly advisable to ensure that the PEP checklists you are using are up-to-date.
In addition, HM Treasury have issued a Financial Sanctions Note in relation to Libya.
Helen Burgess, Membership Manager