Appendix B
Anti-Money Laundering (AML)
Money laundering (including terrorist financing and the proliferation of nuclear, chemical or biological
weapons) have been identified as major threats to the international financial services community and
therefore to Barclays.
The UK, in common with many other countries, has passed legislation designed to prevent money laundering
and to combat terrorism. This legislation, together with regulations, rules and industry guidance, form the
cornerstone of AML obligations for UK firms and outline the offences and penalties for failing to comply.
The requirements of EU⁄UK legislation apply to Barclays globally. Group companies may have additional local
policies and procedures designed to comply with their local legislation, regulations and any government-
approved guidance in the jurisdiction(s) in which they operate. The principal requirements, obligations and
penalties currently in force, on which the Barclays AML prevention approach is based, are contained in:
The Proceeds of Crime Act 2002 (POCA), as amended
The Terrorism Act 2000, as amended
The Terrorism Act 2006
The UK Money Laundering Regulations 2017, as amended, transposing the requirements of the EU’s
Fifth Money Laundering Directive
The FCA Handbook of Rules and Guidance (in particular, the “Senior Management Arrangements,
Systems and Controls” (SYSC) Sourcebook, which relates to the management and control of money
laundering risk)
The Joint Money Laundering Steering group (JMLSG) guidance for the UK financial sector on the
prevention of money laundering ⁄combating terrorist financing.
The Barclays Financial Crime Policy and the four associated AML Standards are designed to ensure that all
Barclays businesses and legal entities comply with the requirements and obligations set out in UK and EU
legislation, regulations, rules and industry guidance for the financial services sector. This includes the
requirement to have adequate systems and controls in place to mitigate the risk of the firm being used to
facilitate financial crime. The Standards, which take account of guidance issued by the Wolfsberg Group and
the European Banking Authority, focus on four key risk areas: the customer lifecycle; correspondent
relationships; politically exposed persons; and wire transfers.
The Standards set out the minimum control requirements, which must be complied with by all Barclays
businesses and legal entities, including:
The appointment of an officer responsible for compliance with the UK Money Laundering Regulations
2017 (as amended), and the appointment of money laundering reporting officers of sufficient
seniority, who have responsibility for oversight of business and legal entity compliance with relevant
legislation, regulations, rules and industry guidance
Establishing and maintaining a risk-based approach towards assessing and managing the money
laundering and terrorist financing risks to the group
Establishing and maintaining risk-based customer due diligence, identification, verification and know
your customer (KYC) procedures, including enhanced due diligence for those customers presenting
higher risk, such as:
o Politically Exposed Persons (PEPs),