If you are a CEO, board member or otherwise involved in delivering a business strategy or IT you probably feel like you are walking around with a GDPR (General Data Protection Regulation) gremlin hanging on your back. It’s whispering the words ‘consent’, ‘processing’, ‘big fines’ and lets no forget ‘privacy statement’ into your ears day in, day out and as May 2018 approaches that soft whisper may start to feel like it’s becoming louder and more aggressive. The gremlin is feeding on continuous marketing emails, blogs (but hopefully not mine!) and newsletters arriving in your inbox with the nightmare scenarios for your company if you don’t get a move on and turn your business into a GDPR paradise. Employing their services to do so, of course.
The competence and capability expected of holders of the compliance function has been brought into sharp focus by two final notices issued by the Financial Conduct Authority (FCA) this summer. One holder of the compliance function (the CF10), was fined £75,000 for failing to exercise due skill, care and diligence in performing his compliance oversight role. The other, a would-be compliance officer, had his application for CF10 and the money laundering reporting function (CF11) refused on the grounds of ‘competence and capability’.
We will be explaining everything payment and e-money institutions need to know about getting re-authorised under PSD2 and the impact of MiFID II on fx forward business in two separate briefings on 12 September.
Due to continued growth we are seeking passionate, ambitious professionals to join us as associate directors and a senior compliance associate.
Risk assessments have been a part of the EU Anti Money Laundering landscape for some time now and while 4MLD brought to the fore the need to have documented risk assessments, they are by no means a new concept.
Last year, the FCA sent a 'Dear CEO' letter about ICAAP. For those who don't know, the ICAAP is a process a firm follows to assess the risks it’s facing currently and in the foreseeable future and calculate an amount of capital it should hold as a buffer against those risks.
The letter was a warning that the exercise shouldn't be a quick totting up of sums without any real engagement in the process. It went only to IFPRU investment firms, though BIPRU firms also have to do ICAAPs. Payment and e-money institutions don't have to do an ICAAP but as those who are tackling their re-authorisation application know, PSD2 places strong emphasis on understanding and managing risks.
Last week the Emerging Payments Association announced the finalists for this year’s Emerging Payments Awards. With more than 200 entries from payments related businesses around the world, the awards are testimony to the amazing growth this area of FinTech is experiencing.