TR13/9 - Anti-Money Laundering and Anti-Bribery and Corruption Systems and Controls: Asset Management and Platform Firms

Published: 31/10/2013   Last Modified : 31/10/2013

Preventing financial crime is a vital element to achieving our objective of protecting and enhancing the integrity of the UK financial system. Two areas where firms may be used to facilitate financial crime are money laundering and bribery and corruption.

Why are we issuing this thematic review?

Firms must establish and maintain robust defences and risk management frameworks that identify and mitigate money laundering and bribery and corruption risks. Although previous regulatory action relating to anti-money laundering (AML) and anti-bribery and corruption (ABC) systems and controls failings has focused on the banking and insurance sectors, there are significant risks in other sectors.

So we carried out a thematic review on asset management and platform firms to assess whether this sector is taking adequate steps to mitigate the money laundering and bribery and corruption risks it faces.

Although we found some good examples of risk management – for instance, most firms had relatively well-developed arrangements for the ownership of money laundering and bribery and corruption risks – we found common weaknesses across the 22 firms in our sample. Given the communications we have issued on AML and ABC, we expected the industry to have done more in ensuring they had suitable systems and controls in place.

Thematic Review 13/9

Who is this review aimed at?

This review is aimed at asset management firms, fund administrators and platform firms.

What are the next steps?

We have provided feedback to those firms in our review, but we expect all firms to consider our findings and the examples of good and poor practice to improve their AML and ABC frameworks where necessary. We will be following up with some firms to discuss the actions they should take.

Even though these findings are from our review of the asset management sector, we expect all firms to have appropriate systems and controls in place for AML and ABC. This review, along with the Financial Crime: a Guide for Firms will help firms achieve that.

The examples of good and poor practice are consistent with existing guidance which has already undergone consultation and is part of our Handbook of Rules and Guidance.

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