Financial crime systems and controls during Covid-19:
29/05/2020
In an update to the Business Plan, on 6 May,Financial crime systems and controls during Covid-19: the FCA published new 6 May 2020 guidance update on financial crime systems and controls during Covid-19:
- “Criminals are already taking advantage of the…pandemic to carry out fraud and exploitation scams through a variety of methods, including cyber-enabled fraud.
Those seeking to launder criminal proceeds or finance terrorism are likely to also exploit any weaknesses in firms’ systems”.
The guidance includes practical steps for firms.
- Remain vigilant to the risk of fraud and exploitation scams: firms should continually analyse and amend their control environment to respond to the changing threats; this includes timely reporting of SARs for any new threats.
- Consider how best to re-prioritise AML and CTF activities: the FCA is clear that firms should not address any operational challenges simply by changing their risk appetite. However, firms may need to “re-prioritise or reasonably delay” some AML and counter terrorism financing activities (which could include ongoing customer due diligence reviews, or reviews of transaction monitoring alerts). This should be done on a risk basis and with a clear plan to return to the usual process “as soon as reasonably possible”. Note separate guidance published by the UK Government on 12 May (with, in contrast, no reference to the pandemic) requiring information sharing within corporate groups and a consistent application of AML/CTF controls. https://www.gov.uk/government/publications/cross-border-information-sharing-within-corporate-groups
- Continue client identity verification: the FCA “expects firms to continue to comply with their obligations on client identity verification” and that the list provided of various remote client identity verification methods “does not represent a relaxation of requirements”.
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As well as owning and publishing Comsure's copyrighted works, Comsure wishes to use the copyright-protected works of others. To do so, Comsure is applying for exemptions in the UK copyright law. There are certain very specific situations where Comsure is permitted to do so without seeking permission from the owner. These exemptions are in the copyright sections of the Copyright, Designs and Patents Act 1988 (as amended)[www.gov.UK/government/publications/copyright-acts-and-related-laws]. Many situations allow for Comsure to apply for exemptions. These include 1] Non-commercial research and private study, 2] Criticism, review and reporting of current events, 3] the copying of works in any medium as long as the use is to illustrate a point. 4] no posting is for commercial purposes [payment]. (for a full list of exemptions, please read here www.gov.uk/guidance/exceptions-to-copyright]. Concerning the exceptions, Comsure will acknowledge the work of the source author by providing a link to the source material. Comsure claims no ownership of non-Comsure content. The non-Comsure articles posted on the Comsure website are deemed important, relevant, and newsworthy to a Comsure audience (e.g. regulated financial services and professional firms [DNFSBs]). Comsure does not wish to take any credit for the publication, and the publication can be read in full in its original form if you click the articles link that always accompanies the news item. Also, Comsure does not seek any payment for highlighting these important articles. If you want any article removed, Comsure will automatically do so on a reasonable request if you email info@comsuregroup.com.