JMLSG revisions to Wholesale Markets Guidance

Revisions have been published to the following sections of Sector 18, Part II of the JMLSG AML/CTF/CPF Guidance:

• ML risks in the Wholesale Markets sector and how to assess them;
• CDD (including SDD and EDD) requirements; and
• Specific guidance on Wholesale Subscription Finance in Private Capital Funds, including product-specific risks and firms’ requirements.

💡 The revisions await HMT Ministerial approval before they will become official regulatory guidance.

Relevant firms operating in Wholesale Markets should review the revised sections and make any preparations ahead of their implementation, including impact assessments and procedural updates.

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