In November 2014, we consulted on proposed examples of good practice from two thematic reviews that considered small banks’ anti-money laundering and financial sanctions, and small commercial insurance brokers’ anti-bribery and corruption, systems and controls. We also proposed amendments to our guidance to clarify our expectations in some areas where significant weaknesses persist. 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.
All respondents thought that our examples of good practice were useful to help illustrate what some firms have done to identify, assess and manage financial crime risk. Some respondents were concerned that these examples might be seen as prescriptive and provided areas where they would welcome further clarification. We have made some amendments to our proposed guidance to address these concerns.
The guidance takes effect on 27 April 2015.
We have also published a statement about our expectations in relation to derisking.
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