The changes aim to provide more clarity on the regulator’s expectations so that gaps in financial crime systems and controls can be more easily identified and remedied.
Key changes include:
- Alignment with the Consumer Duty: The Guide now explicitly states that systems and controls should be consistent with obligations set out in the Duty;
- Cryptoassets: Firms registered under the Money Laundering Regulations (MLRs) are already subject to FCA supervision, but the regulator has made it more explicit that cryptoasset businesses should refer to the FCG;
- Proliferation Financing (PF): The Guide has been updated so that PF has been more clearly mentioned where necessary, including referencing the requirement for firms to conduct PF Risk Assessments;
- Transaction Monitoring (TM): The introduction of guidance on how to implement and subsequently monitor TM systems; and
- Sanctions: Updates to the sanctions chapter to include key learnings gleaned from extensive assessments of firms’ systems and controls.
Firms should review the changes to the guidance and ensure that financial crime control frameworks align with the FCA requirements.
💡 Contact us to help you review your control frameworks to ensure they align with the FCAs expectations. Get in touch at: enquiries@plenitudeconsulting.com