BBA has responded to FCA's examples of good and poor practice in banks' financial crime controls in trade finance. It raises several fundamental concerns. Its main worry is that FCA does not appear to be adopting a risk-based approach to financial crime prevention and that some of its suggestions may encourage a tick-box approach rather than a risk-based one. It also asks for clarification on a number of statements FCA made in its guidance consultation and urges FCA not to finalise the guidance until the banks have discussed their concerns with it. (Source: BBA Responds on Financial Crime)