The letter highlights two areas of concern, prevention of financial crime and implementation of the Consumer Duty, and set outs the following principles:
- Staying vigilant against knowingly or unintentionally engaging in fraudulent activities, scams, or money laundering.
- Understanding your financial crime risks by thoroughly assessing your clients, their transaction patterns, and corporate structure.
- Avoiding superficial, checkbox-style compliance measures or outsourcing responsibilities to third parties.
- Establishing strong and effective systems and controls to combat financial crime and money laundering, tailored to your risk profile.
- Ensuring individuals holding the SMF 16/17 positions possess the necessary expertise, skills, and independence.
- Acting promptly by sharing and reporting any information about misconduct with the FCA and relevant law enforcement agencies.
- Embracing the FCA’s Financial Crime Guide (FCG) and Financial Crime Thematic Reviews (FCTR), which provide a roadmap for firms to protect themselves against financial crime.