Here are my thoughts and comments, which I trust our readers will understand come from my personal perspective: 

• First of all, what  about the failure of the regulations to issue a strict definition of the term Beneficial ownership ? You cannot leave this to industry interpretation, as HM Treasury suggests. Money launderers always like to drive a lorry through any gaps they find. This could be one, if Treasury is does not close this loophole.
• The prohibitions on anonymous accounts, dealing with shell banks and nested banks, (where a bank you wouldn't do business with gains access through a correspondent bank of yours), in Rule 11 is good.
• The 2000 Pound threshold on casino customer due diligence may be a bit low, and will cause the casino industry to incur considerable expense.
• Simple due diligence and enhanced due diligence provisions, Rules 9 & 10, are adequate and necessary, in my humble opinion.
• Politically Exposed Persons (PEPs), in Rule 10(7), is sufficient, as are those regarding High Risk customers, contained in Rules 11 & 14.
• The fact that one cannot reply upon 3rd parties for customer due diligence checks, even if those parties are regulated, is a shortcoming, but perhaps it is finally time to dispense with that time-honored practice, as the best due diligence is that performed personally in-house, for which there is no substitute.
• Are the new record retention requirements excessive and will they be costly ? I wonder about the expenses that will be incurred.
• Finally, what about SAR filers: Can we protect them in some way ?

I trust that my own problems with the Draft will be addressed; notably, The Law Society of England & Wales has strenuously objected to several of its shortcomings. We shall follow up on this subject as the year unfolds, and we get closer to the date at which the UK must conform to EU AML standards.