Key focus areas for financial crime supervision include ensuring that firms:
➡️ Do not underestimate the money laundering risks to which they are exposed;
➡️ Implement business-wide risk assessments #BWRA which are complete and comprehensive in covering inherent and residual risks;
➡️ Develop adequate methodologies for generating client risk-ratings appropriately, ensuring third parties are only relied on when appropriate; and
➡️ Are conscious of the connection between weak money laundering controls and weak market abuse controls, ensuring that reviews of controls are holistic.
✅ Wholesale brokers regulated by the FCA should review their governance frameworks covering the outlined focus areas and ensure they maintain robust controls in line with the regulator’s expectations.