Sanctions Framework Review
Challenges For FirmsAt Complyport, we help firms tackle the emerging issues of insufficient policies and procedures, and levels and quality of customer data that prevent firms from adequately screening or discounting potential matches against the sanctions lists In such urgent situations, people often think that they don’t have time to examine their systems and try to correct any failures. However, an investment of time now could be majorly impactful to increasing efficiency and productivity.
The Regulator’s PerspectiveFirms also need to be prepared for where the FCA’s attention may turn once matters start to return to normal. Whenever an increase or unprecedented level of sanctions are applied (and especially right after a pandemic), the regulator is likely going to be focusing heavily on the following areas post-event:
- Testing the Operational Resilience within firms
- Undertaking thematic, supervision, or desktop regulatory reviews to ascertain if
- A firm’s sanctions systems and controls were sufficient to allow the identification of whether an exposure existed and was controlled
- A firm had an exposure and didn’t control it, or
- A firm could not tell if it had an exposure at all.