The Financial Conduct Authority ('FCA') expects firms to take reasonable care to establish and maintain effective systems and controls for compliance with applicable requirements and standards under the regulatory system, and for countering the risk that a firm might be used to further financial crime.
Reasonable for one firm, may be excessive or insufficient for another. Applicable requirements and standards also vary, depending on the type of activity undertaken, the nature of internal controls and also, the extent to which activity undertaken is susceptible to any inherent risk of fraud, dishonesty or other impropriety. A firm's ability therefore, to articulate what is reasonable could influence the level of interest (or intervention) pursued by the regulator.
As a Regulator the FCA:
Senior Management should ensure clarity of responsibility and accountability in the financial crime framework, and that internal arrangements:
FCRM assists clients to prepare for regulatory review or external scrutiny, to document the control framework and provide (or ensure) clarity of role/responsibility for financial crime in the organisational framework and across the operating environment.
We provide independent advice and objective challenge to the 'status-quo', assisting clients to identify and where necessary, remediate potential gaps in financial crime strategy and the operational framework, to promote compliance with regulatory requirements for financial crime.