Mark Steward has spoken on the importance of “purposeful” AML controls. He headlined:
- the current prosecution for failings in systems and controls to monitor and scrutinise significant cash deposits, and the two large sanctions imposed for other systems and controls failings. He commented that, in some cases, the red flags were not hard to spot, but were somehow ignored;
- the extra-territorial consequences of breaches;
- the importance of a good control environment that can identify signals, and is properly calibrated;
- that FCA currently has 42 ongoing AML investigations into firms and individuals (25 into firms, 17 into individuals), including on PEPs, customers with cash intensive operations, correspondent banking, trade finance and transaction monitoring; and
- emerging risks – online promotions and unregistered crypto businesses