Research and analysis

The Money Laundering and Terrorist Financing (High-Risk Countries) (Amendment) (No. 2) Regulations 2023: RPC Opinion (Green-rated)

Regulatory Policy Committee on HMT's Money Laundering and Terrorist Financing (High-Risk Countries) (Amendment) (No. 2) Regulations 2023 IA

Documents

RPC Opinion: The Money Laundering and Terrorist Financing (High-risk Third Countries) (HRTC) (Amendment) (no.2 Regulations 2023)

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Details

This legislation will update the UK’s HRTC list to reflect the latest country additions and removals made by the (Financial Action Task Force) FATF in 2023.

As originally submitted for RPC scrutiny, the IA was not fit for purpose due to the RPC assessing the IA as having inconsistent assessment of costs and benefits over two different appraisal periods, and unsupported assumptions relating to the calculation of the EANDCB. The IA now contains a proportionate assessment of the direct impacts on business, appraised consistently over an appropriate ten year period. The department has tested key assumptions and provided a suitable counterfactual estimate. The Small and Micro Business Assessment (SaMBA) is proportionate and fit for purpose, although the IA would benefit from addressing the data discrepancy to identify the most accurate number of SMBs that will be impacted by the proposal.

Published 12 December 2023