Emma RadmoreFCA has published the key findings, and examples of good and poor practice, following its assessment of the sanctions systems and controls firms have in place specifically in relation to the increased sanctions following the Russian invasion of Ukraine. Following a review of 90 firms, FCA has concluded that:
- firms that had planned in advance for increased sanctions were unsurprisingly better prepared to implement them quickly;
- some firms were not able to show that senior management was receiving the right MI to make an accurate assessment about their exposure, or were too reliant on global sanctions policies that are not aligned to the UK regime;
- some firms did not have adequate resources to enable them to ensure effective screening, and had dangerous backlogs;
- some firms had not properly calibrated their screening tools, and some relied heavily on third party providers without supervising them adequately;
- low quality KYC and CDD and backlogs in those processes increases the risks of firms not identifying sanctioned individuals; and
- some firms were not reporting potential breaches or relevant information to FCA as quickly as they should.