Following a consultation, the FCA has made changes to its Financial Crime Guide.
The changes cover the following areas:
- The FCA conducted extensive assessments of firms’ sanctions systems and controls following Russia’s invasion of Ukraine, and has updated the relevant chapter of the Guide to reflect these learnings;
- Proliferation financing is now explicitly referenced throughout the Guide where appropriate, including highlighting the 2022 amendment to the MLRs which requires firms to conduct proliferation financing risk assessments;
- There is now key guidance for firms on how to implement and monitor transaction monitoring systems, including supporting responsible innovation and new technological approaches;
- Cryptoasset businesses registered under the MLRs have been subject to FCA supervision for financial crime purposes since January 2020, and the FCA has made clear that such businesses should refer to the Guide; and
- The Guide now makes clear that firms should consider whether their systems and controls are consistent with their Consumer Duty obligations.
There were also consequential changes made to replace expired links, update outdated references to EU rules, and refresh case studies based on more recent FCA enforcement notices.