In October 2013, the Financial Conduct Authority (FCA) published the much-anticipated report of its thematic review into anti-money laundering (AML) and anti-bribery and corruption (ABC) systems and controls at asset management and platform firms. The report follows the FSA/FCA’s previous thematic reviews of ABC controls in commercial insurance broking (2010), ABC controls in investment banks (2012), and AML and sanctions controls in trade finance (2013). As with other thematic work, whilst the review is of a particular sector, the FCA expressly expects other regulated firms to consider the findings and examples of good and poor practice.
The FCA found a number of common weaknesses across firms, particularly in relation to ABC controls. “Most firms” failed to demonstrate adequate systems and controls for assessing bribery and corruption risks posed by third parties and for monitoring third party relationships, and had “more work to do” to ensure that bribery and corruption risks were appropriate mitigated. By contrast, whilst there were shortcomings in some firms’ AML procedures in relation to (in particular) risk assessment and higher risk customers, most firms had a comprehensive suite of AML policies and procedures.
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