Sarah Pritchard has spoken on the importance of firms calibrating their financial crime fighting systems to the right level. She stressed the importance of firms understanding who their clients are, identifying the sorts of transactions they would be expected to make and having in places systems to flag suspicious activity. But she said a tick box approach that planned for the worst is not the way forward. And neither is an off the shelf package or controls operated by an unsupervised third party. She discussed the PEP review, noting that if the PEP rules are not applied appropriately, this can lead to PEPs and their families being excluded from services. FCA’s guidance is clear that UK public figures should generally be treated as lower risk than foreign PEPs.
She ended by saying that reducing financial crime is one of FCA’s “key super-charged priorities” for the year ahead. She noted that in the last financial year FCA carried out 352 proactive assessments of sanctions, and has opened more than 610 financial crime supervision cases – both representing a huge increase on the previous year.