The letter sets out key outcomes for Electronic Money Institutions (EMIs), Payment Institutions (PIs), and Registered Account Information Service Providers (RAISPs).
Prominent amongst these outcomes is protecting the integrity of the UK financial system, with financial crime as one of the focus areas.
Key takeaways from the letter include:
➡️ Governance and Oversight: The FCA noted how weaknesses remain in some firms’ systems and controls, and devoted a specific section to the importance of governance, oversight and leadership in delivering the intended outcomes. This notably includes governance and reporting arrangements that are effective and proportionate, and robust oversight of agents, distributors and outsourced functions
➡️ APP Fraud: Firms’ should ensure good customer outcomes when tackling APP fraud in line with consumer duty obligations. It is worth noting that the FCA drew attention again to their October 2023 Dear CEO letter on this topic, which highlights its importance.
✅ EMIs, PIs, and RAISPs should ensure their governance frameworks and fraud prevention processes are robust, effectively mitigating financial crime risks, especially as this is a recurring topic in Skilled Person reviews and recent enforcement actions.
💡 As a member of the FCA’s Skilled Persons Panel on Financial Crime, Plenitude conducts independent reviews on behalf of the regulator or supports firms throughout the process. Visit our website for more information: https://www.plenitudeconsulting.com/services/s166-skilled-person