Regulatory Roundup 31 included an article on FSA guidance on financial crime which had been published in the form of a consultation paper (CP11/12).
The final guidance (PS11/15) has now been published. The guide will be relevant to all financial services firms and sets out the FSA’s expectations in relation to firms’ financial crime systems and controls.
The regulator confirms that the guidance should be applied in a “risk-based, proportionate, outcomes-focussed way” and that the examples of good practice in the guide provide ways, but not the only ways, of meeting its requirements. Nevertheless firms should find the guidance a useful tool in their compliance with SYSC 6.1.1 (“A firm must establish, implement and maintain adequate policies and procedures …. for countering the risk that the firm might be used to further financial crime”). The FSA has slipped in reference to the published guidance by way of SYSC 6.1.1A.