The FCA has published a Summary of feedback received to its proposed examples of good practice to be included in its guide to Financial Crime, derived from the recent thematic reviews of small banks’ anti-money laundering and financial sanctions, and small commercial insurance brokers’ anti-bribery and corruption systems and controls.
Whilst the majority of respondents welcomed the proposed amendments, some comments within the feedback have resulted in further refinements to:
- the Glossary definitions of Source of Funds and Source of Wealth and additional explanatory notes to make clear they are different from the Joint Money Laundering Steering Group’s Source of funds as evidence of identity’; and
- supporting information which now sets out more clearly the non-binding nature of guidance, and the differences between legal or regulatory requirements and examples of good practice, so as to reduce the impression that the guidance could be seen as prescriptive.
Following receipt of the feedback the FCA will amend its regulatory guidance on Financial Crime, however this is still a work in progress.