FCA has written to the Treasury Committee to respond to questions regarding its financial sanctions responsibilities. FCA confirmed that its role was to ensure that regulated firms have appropriate systems and controls to comply with the Government’s sanctions regime. FCA also provides technical support and guidance on the potential impact of sanctions on markets and firms. In June 2022 and as part of its broader transformation programme, FCA rolled out an analytics based tool to test firms’ implementation of sanctions against Russia.
FCA confirmed that it was not aware of any material deficiencies in firms’ sanctions systems and controls. FCA generally found that boards and executive teams of affected firms have tried to be proactive to ensure compliance with sanctions regulation. FCA has increased its assessment work on sanctions controls to pro-actively test compliance. FCA had not identified any different in the adequacy of firms’ sanctions control based on their size and sector.
Issues identified by the FCA focus on:
- effectiveness of firms’ customer sanctions screening process at onboarding and an ongoing basis;
- real time payment screening; and
- implementation of sectoral sanctions.