Following a consultation on proposed examples of good practice relating to financial crime in November 2014, the FCA has published summary of its feedback.
The examples of good practice follow two thematic reviews that considered small banks' anti-money laundering and financial sanctions and small commercial insurance brokers' anti-bribery and corruption, systems and controls.
All of the 20 respondents to the consultation thought that the FCA's examples of good practice were useful to help illustrate what some firms have done to identify, assess and manage financial crime risk. They also said that these would help them approach financial crime compliance in a more proportionate and risk-based way.
Some of those who responded however were concerned that these examples might be seen as prescriptive and provided areas where they would welcome further clarification – two respondents sent the FCA additional drafting suggestions. The FCA has therefore made some amendments to its proposed guidance to address these concerns.
The feedback received relates to: the timing of the guidance; the definition of 'Source of Funds'; the status of our examples of good practice; and the administrative burden.
The FCA proposes to include these examples in its guidance, 'Financial crime: a guide for firms'. Click here for the full summary of feedback received.
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