May 2018 will stand out as red-letter month on the calendar of Governance Risk and Compliance (GRC) leaders.
Firstly, on 11 May 2018 the new FinCEN Customer Due Diligence (CDD) Rule, providing for beneficial ownership, became effective in the US. Secondly, the UK announced in the first week of May 2018 that the 14 British Overseas Territories will be required, by 31 December 2020, to have created public beneficial ownership registers for companies registered in their jurisdiction. Thirdly, the Council of the EU formally adopted the 5th Money Laundering Directive (MLD5) on 14 May 2018 and, fourthly, to just really spice GRC up even more, the European Union’s new General Data Protection Regulation (GDPR) became effective on 25 May 2018.
We have in previous alert articles drawn attention to the vanguard role adopted by the UK in anti-money laundering (AML) and anti-bribery and corruption (ABC). The UK Bribery Act as a model