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The latest paragraphs for you to consider including in your CQS CPMS Policy.

Text for CQS CPMS Policy

CQS Policy: High-risk Third Countries - Update to reference (FATF)

Purchase this policy: Anti-Money Laundering Policy

Change date
16/05/2024
Word count
103
Deployment measure
7/10
Rationale

Firms need to update your section on HRTCs to reflect the latest changes. HRTCs are now defined as those the Financial Action Task Force (FATF) lists as countries subject to calls to action and increased monitoring.

The firm will apply Enhanced Due Diligence (EDD) measures in any transaction or business relationship with a person established in a high risk third country (MLR 2017 regulation 33(1)(b)). The list of high risk third countries is set out in …

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