Work in progress

The risk-based approach (RBA) officially launched in the UK at the end of August when the revised Joint Money Laundering Steering Group (JMLSG) Guidance and the Financial Services Authority (FSA) Handbook amendments – removal of the ML sourcebook and the new requirement to appoint a senior manager with responsibility for anti-money laundering (AML) – took effect. Three months into the new regime, Debbie Ward and Gavin Coles of Ernst & Young spoke to Timon Molloy about how firms are adapting.

Debbie Ward may be contacted on tel: +44 (0) 20 7951 4622; email: dward1@uk.ey.com. Gavin Coles can be reached on tel: +44 (0) 20 7951 1761; email: gcoles@uk.ey.com. Information about Ernst & Young AML services may also be found at www.ey.com/uk/AML

Foundations of the Risk-based approach

Ernst & Young have worked with a number of organisations throughout the development of the RBA, and coupled with contacts across the regulated sector have formed clear views on the emerging industry trends. It appears that the risk factors are fairly common in nature, but the way in which they are being used varies from firm to firm.