On 13 September, an article from Clyde & Co refers to a recent “Dear CEO” letter sent jointly by the FCA and Prudential Regulation Authority (PRA) in the UK to firms that carry out trade finance business provided a clear and unequivocal message around the expectation of regulators with regards to trade-related financial crime risk assessments. It is reported that the letter said that the FCA and PRA “have found that firms have either failed fully to assess these risks, are unable to evidence the checks they have undertaken, or in some cases discounted them inappropriately” and it sets out the expectation that firms should conduct a robust financial crime risk assessment that covers risks including money laundering, sanctions evasion, terrorist financing and fraud, and contains some suggested steps for firms to consider when performing a trade-related financial crime risk assessment.
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