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https://www.step.org/industry-news/uk-government-releases-guidance-new-daml-exemption-provisions

The UK Home Office issued guidance on the defence against money laundering (DAML) reporting exemption provisions in the Economic Crime and Corporate Transparency Act 2023.

The Act, which received royal assent in October 2023, amends the Proceeds of Crime Act 2002 (the 2002 Act) by introducing two new reporting exemptions from the principal anti-money laundering offences (AML) under the 2002 Act for regulated firms.

The first of these amendments increases the threshold amount for a DAML application from GBP250 to GBP1,000, when a firm wishes to terminate a business relationship with a customer or client. This exemption applies to the whole of the AML-regulated sector, widening the scope to include sectors such as the legal sector and accountants. However, firms must have complied with their existing customer due-diligence (CDD) duties under the Money Laundering Regulations 2017 before paying away. This will undoubtedly be a comforting clarification for such sectors, says law firm Eversheds Sutherland, but the CDD requirement ‘may prove difficult to satisfy and create an additional layer of operational risk’. Firms seeking to exit a relationship for financial crime reasons will need to check before doing so that they have up-to-date CDD information in place, if they intend to rely on this provision.

The second amendment allows firms to pay away money or other property from a customer's account where they know or suspect that part of the funds or property therein constitute criminal property, provided that the amount in the account equals or exceeds the amount to which the knowledge or suspicions are held. This exemption allows firms to pay away funds that the firm deems legitimate, even where those are commingled with suspicious funds. A firm can thus continue to allow a customer to transact where money laundering is suspected, provided the firm retains at least the value of assets to which their suspicions relate. Previously, firms in such a position have had to seek a DAML for the full amount of the account, rather than only the funds linked to suspicious activity.

This exemption also marks a welcome change to the existing DAML regime, says Eversheds Sutherland, although the guidance does not detail how the exemption is intended to operate in practice. It is not clear how a firm will ensure that the portion of funds representing criminal property is not inadvertently paid away as a result of only partial blocks being applied to an account.

'Crucial questions on how to apply this new regime have been left unanswered [and] it is hard to see how firms will get comfortable with operating the provisions in practice', says Eversheds Sutherland. 'Given a [suspicious activity report] will still be required in any event, it may be that most firms decide to include a request for a DAML as a belt and braces approach, particularly where a specific case can’t be tied neatly into one of the new reporting exemptions.'