Correspondence
Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (SI 2017/692)
3.In our last Report,4 we drew attention to this instrument and two others which give effect to updated global standards for combating money laundering, terrorist financing and other threats to the international financial system. The instruments will have a significant impact: in all, over three and a half million businesses are covered by these Regulations but no figures on the likely cost of the legislation were included in the Explanatory Memorandum (EM) and HM Treasury only published the final Impact Assessment (IA) more than two weeks after the Regulations were laid. We felt this showed a lack of appropriate concern by the Government over the Parliamentary scrutiny of secondary legislation and we wrote to the Minister to seek his comments. The correspondence is published at Appendix 1.
4.While the Minister’s response is persuasive about the need for meeting the transposition deadline, we are less convinced by his reason for the delay in the IA: if the Regulatory Policy Committee is an independent body why were its analytical processes interrupted by the General Election? Even if the final IA was not available, we do not understand why HM Treasury could not have put “provisional” or “indicative” figures in the EM to assist Parliament.
4 2nd Report, Session 2017–19 (HL Paper 8).