The FCA identified examples of both good practice and areas for improvement under 5 key themes:
- Governance and oversight;
- Skills and resources;
- Screening capabilities;
- Customer Due Diligence (“CDD”) and Know Your Customer (“KYC”) procedures; and
- Reporting breaches to the FCA.
Firms should view the assessment summary, evaluate their approach to identifying and assessing sanctions risks, and consider appropriate action, where appropriate.