GDF welcomed the opportunity to respond to HM Treasury’s technical consultation on proposed amendments to the Money Laundering Regulations (MLRs). We strongly support HM Treasury’s efforts to modernise the UK’s AML/CTF framework in a way that is clear, proportionate and internationally aligned.
This submission reflects our members’ commitment to a principles-based, technology neutral and risk-based approach that both protects market participants and promotes sustainable growth. They key points of feedback from our membership are as follows:
- We strongly support the removal of dual registration and believe that reducing duplication between regimes will strengthen the overall AML/CTF framework;
- We support the expansion of the scope of the fit & proper tests but with a proportionate application that does not disadvantage start-ups and smaller players;
- We support tailoring the controller/change in control regime to the governance structures of crypto firms;
- We recommend clear transitional arrangements for firms moving to the updated MLR requirements to allow firms time to adapt without disrupting compliance.
- We recommend clear industry specific guidance or supervisory messaging to ensure consistency in approach.