The FCA has issued a consultation document about proposed changes to the annual financial crime reporting obligation for certain firms – the Annual Financial Crime Report, introduced in 2016, which provides the FCA with information on a range of indicators that reflect the potential money laundering risk of a firm, based on its regulated activities and the nature of its customers.  For example, it says, a firm could be more exposed due to the risk profile of its clients and the jurisdictions in which it operates, calling this the ‘inherent ML risk’ of the firm.  Currently, approximately 2,500 out of the approximate 23,000 firms the FCA supervises have to submit such reports, based on the current threshold obligations explained in the document.  The FCA proposes to extend the scope of firms required to provide reports to include firms that carry on regulated activities that it considers potentially pose higher money laundering risk, irrespective of a firm’s revenue threshold.  The FCA also proposes to removing certain activities (“home finance mediation” and “making arrangements with a view to transactions in investments”) from the requirement to file the reports, as these are considered by the FCA to be outside of the scope of the money laundering regulations.  The consultation closes on 23 November.

Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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