For the first time, the US Office of Foreign Assets Control (OFAC) has reached out to provide guidance to firms on creating and maintaining an effective sanctions risk mitigation framework. The guidance is primarily based on the essential criteria which OFAC regards as the tools necessary for firms to achieve their business aims, whilst also mitigating the inherent sanctions risks facing them.
Last year saw an unwelcome re-emergence of the so-called ‘laundromat’ scandal; the term, which harks back to the dry-cleaning establishments into which Al Capone and the Chicago mob funnelled their ill-gotten gains, was popularly attributed to a large-scale criminal money laundering scheme (uncovered in 2014) in which $20.8bn was laundered out of Russia through 96 countries and, more recently, to the rapidly developing scandal involving Danske Bank and its Estonian subsidiaries.
Whether you call them cryptocurrencies, cryptoassets or virtual assets, these tokens and their underlying technology, Distributed Ledger Technology (DLT), remain at the forefront of regulators thoughts, often operating in an unregulated or semi-regulated world which sits somewhere between a land of opportunity and the wild wild west.
Under PSD2, all payment services providers, including credit card providers, money remitters and e-money issuers, account information service providers (AISP) and payment initiation service providers (PISP) are required to file reports in relation to confirmed fraudulent activity, known as the REP017 report.
The REP017 report provides the means for firms through Gabriel to provide the FCA with statistical data on fraud related to different means of payment which in turn is aggregated and shared with the European Banking Authority and European Central Bank.
The first submission for REP017 is scheduled for 31st January 2019 covering the period from the 13th January 2018 to 31st December 2018. For this period, the FCA have published an interim REP017 report to be completed.
This blog aims to give a high-level overview of who REP017 applies to, what transactions it captures and how the data on fraudulent transactions need to be categorised.
fscom is delighted to announce its appointment of Tony Brown as our new Senior Manager in Financial Crime.
Tony brings with him over 15 years of financial services experience to the team specialising in Anti-Money Laundering and Financial Crime Prevention.