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Makes available the latest paragraphs for you to consider including in your CQS CPMS Policy.
text for CQS CPMS Policy:
CQS Policy: Financial sanctions v. AML (Upgrade)
Purchase this policy: Sanctions Policy
Change Date : 14/01/2026 | Word Count: 61 | Deployment Measure : 7/10
Rationale:
Updated paragraph partially based on SRA 2025 guidance. This version provides updates based on legislative changes and recent proactive supervision.
AML beneficial ownership is triggered where an individual owns more than 25 per cent or more of the shares of a body corporate under the money laundering regulations, whereas the
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