The FCA has published a 10 minute webcast aimed at Consumer Credit firms to highlight the requirements placed upon them to mitigate financial crime.
While there should be nothing new for other FCA regulated firms it is worth investing 10 minutes of your time to watch the webcast as a reminder of the high level requirements.
Key issues
- Firms should have sufficient systems and controls in place to effectively reduce financial crime;
- Systems and controls should be proportionate and risk based;
- Firms should assess the risk associated with the products and services it offers and the risk these activities bring about;
- Firms should have enhanced procedures for higher risk scenarios such as when customers are not seen face to face;
- The risk assessment should be regularly reviewed;
- Policies and procedures should in place to mitigate the risks;
- Staff should trained and do they have access to the policies and procedures;
- Firms should have effective governance in place;
- Monitoring should be continuous;
- Data security is key;
- Firms must carry out, where appropriate, adequate customer due diligence;
- Due diligence should be updated regularly;
- Staff should be aware what suspicious transactions are;
- Firms must comply with record keeping requirements.
The FCA web pages about financial crime can be accessed here.
Financial crime is ever evolving and you need to ensure you have robust processes in place to keep up with the ‘industry’.
How secure are you?
ATEB has an audit that has been specifically designed to analyse firms’ approach to financial crime. It looks in depth at:
- Organisation – Governance and Oversight (Systems and Controls);
- Policies and Procedures;
- Financial Crime and Anti-Money Laundering;
- Bribery and Corruption;
- Data Security / Data Protection;
- Fraud;
- Financial Sanctions;
- Whistleblowing;
- Reporting;
- Physical Security.



Financial Resilience Survey – General Insurance
Michael Senior Compliance FCA
The FCA Financial Resilience team has clarified the intention behind the data requested in their survey in relation to Question 2b. Question 2b, Please provide how much of your cash inflows advised in 2, is ‘contractually committed’. The online FAQ, gives the guidance … “We want to identify how much of your estimated cash inflow […]