Investment Management includes both discretionary and advisory management of segregated portfolios of assets (securities, derivatives, cash, property etc) for the firm's customers. In terms of money laundering risk, there is very little difference between discretionary and advisory Investment Management. In both cases, the firm may itself physically handle incoming and outgoing funds, or IT may be done entirely by the client’s Custodian.
In most cases, all money and other assets within the portfolio are held under control of a UK Regulated Custodian with money paid to or from the customer through their UK Bank or Building Society. Investment Management is not a mechanism for the movement of assets from one person to another and therefore the risk of money laundering is relatively low. However, the risk will increase when dealing with certain types of customer, such as Offshore Trusts/Companies, PEPs and Customers from a higher risk non FATF Jurisdictions and the risk may also be affected by other service features that a firm offers its clients.
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