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February 28, 2025
At the end of November 2024 the FCA published a Policy Statement introducing changes to its Financial Crime Guide (‘the Guide’), which came into force on 29th November 2024. It also published Handbook Notice 124, which set out the specific sections in the Guide which were updated. We have taken the update to the Guide as an opportunity to remind firms about the various elements of financial crime, the FCA’s requirements, and other relevant legislation. This Hot TopICS sets out what the changes in the Guide relate to, and will also serve as a reminder for our clients about the two main issues that firms raise with us.
The prevention of, and protection from, financial crime is a thread which runs through all of the FCA’s strategic, operational and secondary objectives. Financial crime can be any offence involving fraud or dishonesty or handling the proceeds of crime.
In essence, financial crime controls are founded on:
- risk assessments (e.g., of customers, the customers’ ownership and beneficial ownership if they are corporate entities, of introducing third parties, and of the likelihood of the firm being used for the purposes of financial crime – which can depend on a number of factors); and
- MI assessments (which can include sanctions data).
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