Financial Crime

It may be recalled that last November the FCA issued Guidance Consultation GC14/7 (see Regulatory Roundup 60) proposing amendments to Parts 1 & 2 of the Financial Crime Guide (FC).

The FCA published a summary of feedback received, which gave rise to several minor changes to the guidance.

Part 1 has been enhanced to provide examples of financial crime MI and defines ‘source of wealth’ and ‘source of funds’ – distinguishing the latter (meaning the activity that generated the funds used in a business relationship)  from the ‘source of funds’ that appears in the JMLSG Guidance (meaning satisfying standard customer due diligence requirements in the situation where payment is drawn on an account in the customer’s name with a regulated credit institution).

Part 2 includes incorporation of new chapters 16 (relating to the management by small banks of money laundering risk and sanctions risk) and 17 (relating to managing bribery and corruption risk in commercial insurance broking).

The FCA is in the process of amending its regulatory guidance (FC) – which takes effect on 27 April 2015 – although the amendments can be found at the link provided.

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