Financial crime prevention guidance for consumer credit firms

24 November 2016

The FCA recently published guidance to protecting your firm from financial crime. The guide gives examples of good and bad practice for consumer credit firms. The guide is a high level interpretation of the requirements, with links to the relevant guidance. It covers:

  • Risk assessment
  • Policies and procedures
  • Governance
  • Staff awareness
  • Data security
  • Anti-money laundering
  • Customer due diligence (CDD)
  • Enhanced due diligence (EDD)
  • Ongoing monitoring and suspicious activity reporting
  • Record keeping

It is important for each firm to assess its own AML risks and take the proportionate action. Those risks will differ from firm to firm depending on the regulated activity and business model.

As there may be more than one regulatory body responsible for monitoring financial crime risks at firms, businesses need to remain diligent to the requirements of each regime. For instance both HMRC and the FCA supervise firms with respect to Money Laundering Regulations (MLR) depending on what activities are conducted by the organisation.

On 11th November 2016 the FCA also finalised the requirements for completing a new Financial Crime Return form, known as REP-CRIM. Click here for more information and to assess whether your firm will be required to complete the return.

At Bovill we help firms to put in place appropriate systems and controls or arrange staff training to ensure you comply with the applicable regulatory regime. Contact us if you have any questions regarding your financial crime framework.

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