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One
of the FSA’s objectives is to reduce financial
crime. Revised guidance on
anti money laundering legislation (the Joint Money
Laundering Steering Group notes) focus’s more
widely on ‘financial crime’ rather than
previous perceptions of this only relating to terrorism.
Following the issue of this revised guidance, firms
are required to carry out a risk assessment of their
own potential
exposure to financial crime. This includes reviewing
client profiles, product types and operating locations.
More emphasis is now being placed on firms having
appropriate risk assessed financial crime policies,
systems and controls. Regardless,
firms still need to ensure that they routinely
and effectively carry
out money laundering identification verification
checks on their clients and
ensure that this information is being kept up
to date. Many previous regulatory fines regarding
money laundering have not so much related to firms
being used for or being involved in money laundering
but related to failing to implement appropriate
systems and controls to identify their clients.
Prevention is very
much better than the cure in this case.
Gem Compliance can review your
existing financial crime policies, systems and
controls and identify any amendments required
to bring these up to the
standards required by the revised guidance notes.
We can make sure that your systems and controls
are effective and efficient, but also risk assessed.
We
can also make sure that your staff understand
their own obligations under the rules, both for
all employees of regulated firms but also for
those staff more closely involved in client facing
relationships and also senior management.
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