Speaking at the FSA’s financial crime conference, Tracey McDermott (acting director of enforcement and financial crime) explained that the Financial Conduct Authority (FCA) will assume the FSA’s responsibilities on financial crime and will continue to focus on “the use of firms as a conduit for financial crime”
The guide is available for consultation until September and includes a number of good and poor practices, broken down into key areas such as:
Systems & Controls
Senior management should take responsibility for financial crime risks with appropriate reporting lines. Management should be keeping up to date with financial crime issues and share these with other staff within the business.
Staff competence should be reviewed and businesses should only employ staff who possess the skills, knowledge and expertise to carry out the role effectively and have effective vetting and training in place.
The firm should have appropriate oversight checks/audit to test the business against financial crime.
Anti-money laundering
Has the firm appointed a money laundering reporting officer (MLRO), does he/she have the resources and experience to carry out the role effectively, and are reporting lines in place?
Is appropriate customer due diligence checks made? Is appropriate ID obtained and verified, are you over reliant on electronic checks. Do you have enhanced due diligence if dealing remotely with customers? – Additional checks on ID provided, sources of any funds evidenced.
Fighting mortgage fraud
Do you request original documentation even if the lender does not require this? Do you check information provided to you is consistent with the customer profile and other information on file? Do you establish why a case has been declined?
Further information on the full guide can be found here