At A Glance
Fast takeaways for decision-makers.
- 1Sanctions: In response to Russia's illegal invasion of Ukraine in 2022, the FCA conducted extensive assessments of firms' sanctions systems and controls. The updated guide will reflect the lessons learned by both the FCA and firms during this process.
- 2Proliferation Financing (PF): The guide will be updated to explicitly reference PF throughout the document where appropriate. It will also highlight a 2022 update to the Money Laundering Regulations (MLRs) that requires firms to carry out PF Risk Assessments.
- 3Transaction Monitoring: The revised guide will provide key guidance for firms on implementing and monitoring transaction monitoring systems. It will also support responsible innovation and new approaches, such as the use of Artificial Intelligence.
- 4Consumer Duty: The revised guide will emphasize that firms should consider whether their systems and controls are proportionate and consistent with their obligations under the Consumer Duty.
The Financial Conduct Authority (FCA) is requesting consultations on a new revised version of their Financial Crime Guide, CP24/9. The proposed updates to the guide are as follows:
- Sanctions: In response to Russia's illegal invasion of Ukraine in 2022, the FCA conducted extensive assessments of firms' sanctions systems and controls. The updated guide will reflect the lessons learned by both the FCA and firms during this process.
- Proliferation Financing (PF): The guide will be updated to explicitly reference PF throughout the document where appropriate. It will also highlight a 2022 update to the Money Laundering Regulations (MLRs) that requires firms to carry out PF Risk Assessments.
- Transaction Monitoring: The revised guide will provide key guidance for firms on implementing and monitoring transaction monitoring systems. It will also support responsible innovation and new approaches, such as the use of Artificial Intelligence.
- Cryptoassets: Since June 2020, cryptoasset businesses registered under the MLRs have been subject to FCA supervision for anti-money laundering (AML) purposes. The updated guide will make explicit reference to the fact that cryptoasset businesses should consult the guide.
- Consumer Duty: The revised guide will emphasize that firms should consider whether their systems and controls are proportionate and consistent with their obligations under the Consumer Duty.
- Consequential Changes: The FCA will make consequential changes to the guide, including replacing expired links, updating references to European Union rules, and refreshing case studies based on more recent FCA enforcement notices.
The FCA is inviting stakeholders to provide feedback and input on these proposed updates to the Financial Crime Guide, CP24/9, as part of the consultation process.
In addition to the proposed updates to the Financial Crime Guide, CP24/9, it is worth noting that experienced consultants in the field of financial crime prevention can provide valuable assistance to firms navigating these new requirements. MEMA Consulting, for example, offers expert guidance and support to help firms understand and implement the necessary changes to their systems and controls.
MEMA Consulting's team of seasoned professionals possesses in-depth knowledge of the regulatory landscape and industry best practices. They can work closely with firms to assess their current practices, identify areas for improvement, and develop tailored solutions to ensure compliance with the revised Financial Crime Guide.By engaging with consultants like MEMA Consulting, firms can benefit from their expertise and gain a clearer understanding of the practical implications of the updates related to sanctions, proliferation financing, transaction monitoring, cryptoassets, and the Consumer Duty. This collaboration can help firms strengthen their financial crime prevention measures and align their practices with the FCA's expectations.
For firms interested in exploring how MEMA Consulting can support them in this process, it is recommended to reach out and book a consultation. This will provide an opportunity to discuss specific needs, challenges, and how MEMA Consulting's services can help firms navigate the evolving regulatory requirements effectively.
