The FCA has identified financial crime as one of its top seven risks this year. In an FCA conduct risk briefing published in November 2014, Robert Taylor (the FCA's head of wealth management and private banking) identified the inherent risks involving money-laundering and 'politically exposed persons' or PEPs as among the main risks facing the industry, saying "these issues really need to be top of the agenda within your board room".
The new FCA business plan, delivered on 24 March 2015, supports this by announcing that the FCA is "implementing an enhanced anti-money laundering supervision strategy" and that it will continue "visits to smaller firms that may be exposed to a high risk of being exposed to financial crime".
The most recent pronouncement on the subject was the insertion of a new chapter 16 into the FCA's Financial Crime Guidance, entitled "How small banks manage AML and sanctions risk", which came into effect on 27 April 2015.
In a detailed review of the legislation and regulation, Laurence Lieberman, Partner, and Peter Wilson, provide a road map and practical guidance to private banks and wealth managers in addressing their AML obligations in an article originally published on the Compliance Matters website.