In July 2013, we consulted on examples of good and poor practice in ‘Banks’ control of financial crime risks in trade finance’. We proposed to include these examples in Financial crime: a guide for firms, our regulatory guidance, which sets out our expectations of firms’ financial crime systems and controls.
Most respondents found our examples of good and poor practice useful. But some respondents were concerned that some of our examples of good and poor practice were too prescriptive. They felt that this was disproportionate and incompatible with our risk-based approach. We amended our proposed guidance to address these concerns.
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