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FCA Amendments: Guidance on Financial Crime
Financial Crime Systems and Controls
29 April 2015
Financial crime systems and controls
The FCA have now published the revisions to their Firms Guidance on Financial Crime. In particular the regulator amended Chapter 2 of the Guidance on Financial Crime Systems & Controls on Management Information and Risk Assessments.
Summary of FCA Guidance Amendments:
The FCA’s Financial Crime Guide helps clarify the type of management information that should be collated and provided to a firm’s senior management to ensure that any risks related to financial crime that their firms’ might be exposed to is fully understood.
The FCA advises that Management Information should be provided regularly and ad hoc as risk dictates and will help senior management effectively manage risks and adhere to their firm’s risk appetite.
Financial Crime Management Information Examples:
- The number of transaction monitoring alerts
- Details of any true sanctions hits
- Information about suspicious activity reports considered or submitted, where this is relevant; and
- The number and nature of new business relationships, in particular those that are high risk and the number and nature of business relationships that were terminated due to financial crime concerns.
Management Information may come from more than one source such as a firm’s compliance department, internal audit, customer-facing staff, the MLRO or nominated officer.
The Regulator advises that if a firm is to apply proportionate and effective systems and controls, then having a thorough understanding of the financial crime risks that it is exposed to is vital.
Therefore a firm should identify and assess those risks to which it is exposed to that they can then target their financial crime resources on areas of greatest risk. The firm should identify and assess risks such as:
The regulator informs that business-wide risk assessments should therefore:
Firms, having considered their business-wide risk assessments, should build upon these to determine the level of risk associated with individual relationships. This should:
Whilst assessment of the risks associated with individual relationships can inform, they are not a substitute for business-wide risk assessments, as such firms should review both business-wide and individual risk assessments regularly to make sure they remain current and appropriate.
Click here to view a Summary of the FCA’s Amendments to their Financial Crime Guidance - Chapter 3: Money Laundering & Terrorist Financing
With the importance of firms’ systems and controls making the focus list for 2015/16, the FCA will be looking to target firms with insufficient internal mechanisms in place to minimise the risk of financial crime. As such, firms should be mindful of this need when developing their business strategies and as part of their product governance processes.