APCIMS has responded to FSA’s consultation on the Financial Crime Guide. It feels the guide focuses heavily on larger institutions and does not take into account what measures might be proportionate for smaller firms. It is also concerned that, although FSA says the guide is not for use as a checklist, that is exactly how supervisors will treat it. Its other major concern is the overlap with existing guidance, specifically the Joint Money Laundering Steering Group (JMLSG) Guidance, and the status the FSA Guide will have. (Source: APCIMS Responds on Financial Crime Guide)