The FCA has issued a ‘Dear CEO’ letter to General Insurance Intermediaries setting out its expectations for maintaining adequate arrangements that safeguard client money especially during the coronavirus (Covid-19) pandemic.
It reminds firms of their obligations to continue to oversee the CASS arrangements. It requires firms to discuss the contents of the letter with the board and agree what further action is necessary to help ensure adequate arrangements are in place, highlighting the following areas:
- application of client money rules to firm’s business model;
- governance and oversight;
- oversight of third parties, including due diligence;
- client money calculations and reconciliations;
- acknowledgement letters for all client money accounts.
You can find further information regarding client assets and coronavirus here.
Trust Registration Service – update
John Begg Compliance 2017, 2020, 2021, EU, ML, Pension, PI, Register, transfer, Update
New rules, transposing the Fifth Money Laundering Directive (5MLD) into UK law took effect on 10 January 2020. One impact of the rules was to broaden the scope of the Trust Registration Service (TRS) requirements. you can read more about 5MLD and TRS here. In brief, the previous rules required that all express trusts that […]