Money Laundering Guidance
On 15 December 2007, the UK’s 2007 Money Laundering Regulations became
effective. These Regulations implement into UK law the EU’s Third Money
Laundering Directive – the Directive on the Prevention of Money Laundering and
Terrorist Financing (2005/60/EC).
The Regulations apply to life insurance, and syndicates writing life insurance must
therefore comply with them. They also apply to Lloyd’s members’ agents. General
insurance falls outside the regulated sector covered by the Regulations and,
therefore, most Lloyd’s managing agents are not explicitly covered by them.
Nevertheless, Lloyd’s recommends that managing agents seek to follow the
Regulation’s provisions as ‘best practice’, wherever possible and practicable.
Lloyd’s International Regulatory Risk (IRR) will issue updated guidance shortly,
in consultation with Lloyd’s Market Association.
Sanctions Guidance
To help Lloyd’s managing agents to comply with the requirements of sanctions
regimes, IRR issued Market Bulletin Y4117 International Sanctions Guidance on
14 January 2008.
It has also arranged for Charley Landgraf of US law firm Dewey & LeBoeuf to give a
presentation to the market on compliance with US sanctions, with special
reference to OFAC activities, on 18 February 2008. IRR will give details of this event to compliance officers shortly.
Financial Crime Seminar
IRR is hosting a Financial Crime Seminar for the Lloyd’s market in Lloyd’s Old
Library on 28 March 2008. This all-day event will cover various aspects of financial
crime and its potential impact on Lloyd’s and Lloyd’s underwriters. Speakers will be drawn from various backgrounds, including the FSA, SFO and legal practice. The key note speaker is Robert Wardle, Director of the Serious Fraud Office, and issues covered will include the Independent Insurance Company case and anti-corruption legislation.
Bribery and Corruption Guidance
IRR proposes to issue guidance on bribery and corruption legislation. This will
cover the US Foreign Corruption Act in the US and the recent Law Commission
consultation paper, Reforming Bribery. It is planning to issue this guidance later
in 2008.
