Firms regulated by the Financial Conduct Authority ('FCA') and other UK firms covered by The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 ('MLR'), are required to consider and where necessary to implement and maintain, effective systems and controls to mitigate money laundering risk.
A failure to ensure appropriate compliance with MLR requirements can lead to regulatory sanction, enforcement action and in more serious cases, where money laundering occurs, to the risk of criminal prosecution, financial penalties and/or imprisonment.
FCA regulated firms' anti-money laundering ('AML') arrangements, must include:
A regulated firm's AML framework, inter-alia, includes:
FCRM personnel are experienced AML practitioners, including a former head of the UK's National Financial Intelligence Unit, former Nominated Officer and MLRO, and AML Risk & Compliance specialist.
We have a network of independent AML specialists we can call upon to support delivery of larger advisory and compliance assignments, some of whom are former Big-4 Risk Consulting and AML advisory specialists; and others who are former MLROs' and in-house AML/Financial Sanctions practitioners.