Introductory Breakdown to the Pandora Papers

What are the Pandora Papers? The Pandora Papers is the largest investigation in journalism history, led by the International Consortium of Investigative Journalists (ICIJ), with the leak of around 12 million files that reveal the abuse of the global financial system by individuals, businesses and Politically Exposed Persons (PEPs). Released [...]

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FCA Data on UK Financial Crime

Of relevance to: All firms In a speech by Megan Butler, Executive Director of Supervision – Investment, Wholesale and Specialists at the Financial Conduct Authority (“FCA”), delivered at the Anti-Money Laundering TechSprint event on 22 May 2018, the FCA revealed that 2,100 firms, including all the major banks and life [...]

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REP-CRIM

Of Relevance to: Firms falling within the criteria within SUP 16.23; those persons with responsibility for oversight of financial crime A reminder that a new financial crime data return (REP-CRIM) comes into force on 31 December 2016 – see Regulatory Roundup 75 and 78. The draft rules first appeared in [...]

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Thematic Review: Inside Information

The FCA has published its findings on yet another thematic review – this time looking at ‘Flows of Confidential and Inside Information’ (TR15/13). The review sample consisted of 16 mostly small to medium-sized wholesale firms which the paper describes as ‘investment banking firms’ (however the accompanying article on the FCA website, [...]

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Market Abuse

The FCA has released consultation paper CP15/35 on the revised market abuse regime “Policy proposals and Handbook changes related to the implementation of the Market Abuse Regulation (2014/596/EU)”. The current UK market abuse regime is largely centred around the 2003 Market Abuse Directive (MAD) with UK ‘bolt-ons’ that were based [...]

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Whistleblowing

SYSC 18 promotes, in the sense that it contains guidance rather than rules, the use of the Public Disclosure Act 1998 in making protected disclosures (‘whistleblowing’).  SYSC 18.2.2 specifically encourages firms to adopt internal procedures which will encourage workers with concerns to whistleblow internally about matters which are relevant to [...]

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AML: UK Risk Management

HM Treasury has published the first money laundering and terrorist financing (AML/CTF) national risk assessment (NRA).  It may be recalled that earlier this year it published a supervision report on AML/CTF for 2013-14 – see Regulatory Roundup 64. Chapter 6 concerns the ‘regulated sector’; for the purposes of the paper [...]

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Cyber Security 101: Educate

AIMA, the Alternative Investment Management Association, launched its Guide to Sound Practices for Cyber Security yesterday with a panel discussion hosted by MacFarlanes. The guide is relatively short for such a large subject, but information dense. It is pragmatic and helpful and has been targeted at the hedge fund and [...]

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Money Laundering – Gold

FATF has produced a report on the gold sector as a result of what is seen as a transition of money laundering and terrorist financing from the formal financial sector and the cash market to the gold market as regulators and law enforcement harden those environments. Various case studies appear [...]

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Financial Crime – A Guide for Firms

Background The FCA has published a revision to “Financial Crime: a guide for firms”, effective from 27 April 2015. The amendments come against a backdrop of two thematic reviews published in November 2014 into Anti-Money Laundering (AML) and Anti-Bribery and Corruption (ABC). Whilst the reviews targeted small banks and insurance [...]

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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 [...]

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