FCA's first financial crime conference since its inception featured speeches from, among others, Martin Wheatley and Tracey McDermott of FCA. Recurring themes included:

  • the UK's desire to make itself a "hostile place" for money launderers;
  • increased use of the need for "attestations" by CEOs or senior managers to attest compliance with requirements, which would enable FCA to work towards taking action where merited against senior individuals within firms; and
  • the need for the UK to work hard towards its next FATF evaluation due in a couple of years.

FCA also announced the results of its thematic review on banks' control of financial crime risks in trade finance. Its sample of banks reviewed generally had good controls to ensure they did not deal with sanctioned persons. But FCA found weaknesses in:

  • policies, procedures and controls to counter money-laundering risk, especially in high risk areas; and
  • often poor systems and controls over dual-use goods.

It found large US banks tended to mitigate these risks better than the other banks in its sample. FCA has published examples of good and poor practice and now wants banks to ensure that high-risk customers and transactions are identified and senior management take appropriate action. It also says banks must improve management information so senior management can assess developing risks. FCA says it is considering whether it needs to take any action against any particular bank beyond highlighting areas for improvement. It has also issued a guidance consultation on good and poor practices in banks' control of financial crime risks in trade finance, which it proposes to include as a new chapter in its Financial Crime Guide. It asks for comments by 4 October. (Source: FCA Holds Financial Crime Conference and FCA Publishes Trade Finance and Financial Crime Review and Guidance Consultation: Trade Finance and Financial Crime)