Broken down to its most basic level, an audit is a method by which firms seek an external opinion on their policies, procedures, systems and controls. Rather than an exercise in detecting shortcomings and failures, the process of a compliance audit should be viewed as a means of testing an AML/CTF framework to identify opportunities to undertake enhancements as well as highlighting any issues. In essence, the intention is to provide assurance that the firm is operating in an compliant manner within its own specific regulatory framework.
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 month Standard Chartered bank agreed to pay a $1.1 billion for both Anti-Money Laundering and Sanctions violations. This blog is an overview of the bank’s failures in relation to both cross-border violations and what they mean for firms.
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.
London is the second largest financial centre in the world and financial services is the largest industry in the UK, therefore it is logical to expect the financial services industry to be high on the negotiation table for BREXIT.