The FCA has published a Policy Statement introducing changes to its Financial Crime Guide. Handbook Notice 124, sets out the specific sections in the Guide which have been updated.
In summary, the updates to the Financial Crime Guide;
- relate to sanctions, proliferation financing and transaction monitoring;
- add references to cryptoassets and the Consumer Duty; and
- make consequential changes (such as data security and updating case studies) throughout the guide.
In relation to Sanctions, the FCA has;
- updated the terminology in the Sanctions chapter for clarity and consistency;
- provided clarification about when firms should notify the FCA of suspected sanctions breaches;
- included specific reference to Senior Management responsibility in the Sanctions chapter (FCG 7), stating “We expect senior management to take clear responsibility for managing sanctions risks, which should be treated in the same manner as other risks faced by the business. There should be evidence that senior management are actively engaged in the firm’s approach to addressing the risks of non-compliance with UK financial sanctions. Where they identify gaps, they should remediate them.”; and
- added questions to the firm ’self-assessment’ questions in FCG 7, in relation to Sanctions (e.g., “How are senior management kept up to date with sanctions compliance issues?)
The updated Guide came into force on 29th November 2024.