Advisory and Transformation
AML/CTF/CPF
Industry NewsAnalysis of the background to the fines provides us with details of key areas where deficiencies were observed, and regulated firms should pay close attention to these findings and consider their own controls as a priority for 2023:
➡ AML, AB&C and Fraud systems and controls
➡ Operational risk management and governance
➡ Risk management systems
➡ Risk mitigation
➡ Policies and procedures
➡ Staff training
➡ IT project governance
➡ Customer activity monitoring
➡ Arrangements, systems, controls and procedures
➡ Information publishing
➡ Conducting business with due skill, care, integrity and attention
➡ Management Conflicts of Interest
➡ Oversight and governance
➡ Identification of deficient controls
➡ Treating customers fairly
➡ Trade Monitoring/surveillance
➡ Correspondent Banking
➡ Giving advice to customers
⛔ The FCA’s message is clear: misconduct will not be tolerated.
Their ‘Approach to Enforcement’ provides further insight into their approach:
Conclusion
In addition to enforcement activities and levying of fines and other penalties, the FCA is taking a more proactive and assertive approach to supervision through ‘interventions’, which include wide-ranging powers to impose requirements, restrictions or variation of permissions for firms, often on an urgent basis.
