The FCA has published two thematic reviews:

1. Managing bribery and corruption risk in commercial insurance broking; and
2. How small banks manage money laundering and sanctions risks, following earlier reviews in 2010 and 2011.

The purpose of the reviews is to establish how small firms manage financial crime.

The FCA reviewed ten commercial insurance intermediaries and 21 banks and found that:

• There continues to be widespread weaknesses in banks’ anti-money laundering (AML) systems and controls within the sample reviewed and, in some cases, sanctions controls. In particular, a third of the banks sampled had insufficient resources devoted to AML and sanctions risks, staff have insufficient knowledge of money laundering risks and some overseas banks have difficulty in aligning their group policies with the higher requirements in the UK; and
• Most insurance intermediaries sampled had controls that failed to manage bribery and corruption risk effectively. In particular, bribery and corruption risk assessments were often too narrow and senior management oversight was inadequate.

As a result of these thematic reviews, the FCA has proposed to update the “Financial Crime: A Guide for Firms” to include best practices and to identify areas that firms need to improve.

The deadline for comments on the proposed guidance is 6 February 2015.

Copies of the thematic reviews:

Insurance

Document 1 – http://bit.ly/1BPw0wc<

New webpage – http://bit.ly/1xVTzz9

Small Banks

Document 2 – http://bit.ly/1Am4WTG

New webpage – http://bit.ly/11wX4iW

Guidance consultation – http://bit.ly/1vs8eUa and http://bit.ly/1qOqWOq

Press Release – http://bit.ly/11noJnm