“The Governments approach is to ensure the UK financial system is a hostile environment for money laundering and terrorist finance while minimising the burden on legitimate businesses. In so doing and in order to prevent the UK being put at an economic disadvantage, the UK Government remains committed to the effective implementation of global standards (those agreed by the 36 Member States of the Financial Action Task Force) and the EU 3rd Money Laundering Directive (EU Directive). The implementation of these requirements by the UK is underpinned by the principles of effectiveness, proportionality and engagement; and is driven by a commitment to the risk-based approach provided for in the Regulations. This gives businesses flexibility in their implementation of the Regulations and it helps to avoid the tick-box application of the regulations under which emphasis is placed on formally discharging requirements rather than the substance of effective AML practice. It should help to minimise costs on business and to ensure the Regulations are effective and proportionately implemented on a case-by-case basis, by reflecting the considered judgement of individual businesses of the risks they face.”
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