BBA’s response to FSA’s consultation on the Financial Crime Guide raises a concern over the timing of the publication. It comments there are various international and domestic reviews of anti-money laundering regulation, and it expects developments on prosecution powers for financial crime and new Government strategies. On the content of the Guide, it notes the Guide draws on examples of good and poor practice from thematic reviews on small parts of the industry. It thinks the examples of good practice may lead to the Guide being used as a checklist, which is inconsistent with a risk-based and proportionate approach, although its members found the examples of poor practice helpful. Finally, like APCIMS, it queries what the status of the Guide will be. (Source: BBA responds on Financial Crime Guide)