Buckles Solicitors LLP
1 Contributions by Buckles Solicitors LLP Experts
PRACTICE NOTES
This Practice Note concisely outlines underground banking, covering its background, present applications and the risks that inevitably accompany it. It is directed especially at law practices within scope of the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017), SI 2017/692, and the linked duties to identify and evaluate risk, keep policies, controls and procedures to mitigate those risks, and report conduct that creates suspicion of money laundering or terrorist financing. In March 2023, the Legal Sector Affinity Group (LSAG) also issued an Advisory Notice concerning Chinese underground banking and money originating from China. It clearly sets out the specific dangers presented by Chinese underground banking and the regulators’ expectations around robust due diligence and source-of-funds verification.
What is underground banking?
Underground banking is an umbrella expression for the supply of predominantly informal financial
Practice Compliance
If you expected to see yourself on this page, click here.
