On 21st November, the Financial Services Authority published a public statement about a civil penalty issued against Fedelta Trust Ltd for £73,644 (discounted by 30% to £51,551 due to co-operation by the company). In the key learning points identified for business, the FSA states that s regulated entity’s risk management arrangements, including in respect of AML/CFT, should extend to understanding of the investment and operational activities of its clients – even when the regulated entity is, as a registered agent, providing only limited services to its clients. Not all clients have the same characteristics; and the risks associated with a particular client may not be mitigated by simply applying ‘standard’ processes and procedures.
This blog is primarily for my own use, to keep informed and up to date. However, if you would like to say thank you (and perhaps help me get a new, better laptop when I am away…) you can “buy me a coffee” at https://www.buymeacoffee.com/KoIvM842y