The Financial Conduct Authority (FCA) recently fined a large bank after finding it had failed to take reasonable care to ensure that all aspects of its anti-money laundering (AML) policies were applied appropriately and consistently to its corporate customers connected to politically exposed persons (PEPs). After this decision, it is clear that the FCA is focused on the conduct of AML activity.
Tracey McDermott, director of enforcement and financial crime, said:
One of the FCA’s objectives is to protect and enhance the integrity of the UK financial system. Banks are in the front line in the fight against money laundering. If they accept business from high risk customers they must have effective systems, controls and practices in place to manage that risk.
This was the first time that the FCA concentrated on commercial banking activity in an AML case, as well as being the first AML case to use the new penalty regime. The new penalty regime means that larger fines are likely to be issued by the FCA going forward.
In order to prevent financial crime, all organisations must have effective AML systems and controls in place to ensure that all the participants in financial transactions are subjected to effective and appropriate due diligence. This is particularly important where the transaction involves PEPs or other high risk customers.
Having worked in the regulatory environment for almost 20 years Hazell Carr understands the legal and regulatory requirements placed on firms in respect of AML. The UK regulator continues to focus resources on firms exposed to financial crime and is clearly prioritising customer protection. Hazell Carr can fully support all aspects of this AML activity through supplying skilled resource with the relevant expertise.
The Equiniti Hazell Carr resource pool includes many consultants with substantial knowledge and experience developed over a wide range of projects. These individuals have a great deal of compliance expertise, including specific knowledge relating to the oversight of customer on-boarding, as well as best practice approaches to know your customer (KYC) and AML processes. This resource pool consists of the following:
- Senior AML Consultants – Highly skilled and experienced senior AML consultants with excellent industry relationships and reputations.
- AML Administrators – To handle bulk processing and transactional work.
- Team Leaders – Managers with substantial experience of supervising teams to ensure quality and productivity meets with the client’s expectations.
- Operations Managers – Senior management staff to provide oversight to the project and ensure that all targets and milestones are met.
This panel of flexible resource has been used to deliver a range of client AML projects, as outlined below.
- Providing AML support to operational areas to ensure effective implementation of controls and processes.
- Assisting with compliance issues arising out of combating the financing of terrorism obligations.
- Reviewing suspicious transaction monitoring tools to detect irregular transactions.
- Performing enhanced due diligence reviews for high risk customers opening new accounts.
- Reviewing client financial statements and performing various other searches.
- Reviewing customer and account information and analysing compiled data to identify high-risk customers.
- Approving KYC documentation collected through public record research and other external sources for on-boarding and AML purposes.
- Conducting enquiries on individuals and firms suspected of financial crimes by analysing transaction history, commercial databases and other sources to investigate activities related to money laundering, financial crimes and terrorist funding.
- Conducting full analysis on all accounts and investigative escalation of cases meriting further review.
- Identifying new and emerging frauds from suspicious customer activity and minimising losses by placing cautions and terminations on suspected accounts.
- Ensuring activities and nature of the business relationship is appropriate and in line with the documents collated.
Given the high level of scrutiny the FCA is placing on this area, it is essential that all organisations ensure their AML policies are applied appropriately and consistently. Hazell Carr is well placed to provide relevant expertise and resource wherever required.
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