The UK Financial Conduct Authority’s (FCA) enforcement action against Carphone Warehouse (CPW) featured the second focused resolution agreement that the FCA has entered into. Importantly, this is the first focused resolution agreement that has resulted in a change being made to the financial penalty that the FCA imposed. However, relatively little air time has been […]
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OFAC Emphasizes Importance of Risk-Based Sanctions Compliance Programs for US and International Companies
Further emphasizing its expectation that all companies whose business touches on the United States should maintain a robust, risk-based US economic sanctions compliance program (“SCP”), the US Treasury’s Office of Foreign Assets Control (“OFAC”) has published a detailed “Framework for OFAC Compliance Commitments” (the “Framework”) setting forth the key components of an adequate SCP. OFAC’s […]
Read MoreGuidance on managing the risk of Customer Tax Evasion
The Wolfsberg Group is pleased to publish its Guidance on Customer Tax Evasion, which is designed to provide Financial Institutions (FIs) with an industry perspective on how to develop, implement and maintain an effective anti-tax evasion compliance programme. The overall objective of the Guidance is to promote a culture of ethical business practices and compliance […]
Read MoreLeading the Way on Regulation + A customer-focused culture
The following is part of a Speech delivered by Karina McTeague, Director of General Insurance and Conduct Specialists Supervision, at the British Insurance Brokers’ Association (BIBA) Conference 2019. A customer-focused culture Culture is an acknowledged key root cause of the major conduct failings across financial services in recent history. My initial impression is that the […]
Read MoreFCA ENFORCEMENT CASE STUDIES – Lessons learnt?
LEARN FROM OTHER PEOPLES MISTAKES – Enforcement action was taken by the FCA about 1] culture and governance; 2] operational and technological resilience; 3] financial crime and money laundering, and 4] the treatment of customers. Cases matched against the above are discussed below:- 1.Firm’s culture and governancei it is expected that individual accountability, culture and […]
Read MoreMoney Laundering order amendment
The Minister for External Relations Senator Ian Gorst yesterday made the Money Laundering (Amendment No. 10) (Jersey) Order 2019, which will come into force next week on Wednesday 12 June. Amendment No. 10 makes miscellaneous changes to the legal requirements on firms in relation to customer due diligence and introduces the concept of domestic PEPs […]
Read MoreMoney laundering and tax evasion risks in free ports
A study on Money laundering and tax evasion risks in free ports provides an insight into the money laundering, tax evasion and tax avoidance risks connected with free zones, particularly those that function as (semi-) permanent storage for high-value goods, often referred to as ‘free ports’. Conducted at the request of the European Parliament’s Special […]
Read MoreESTATE AGENTS UPDATED UK AML GUIDANCE (AS AT DEC 2018)
The real estate sector continues to have significant focus from its money laundering regulator – HMRC. Following a crackdown in March, which saw 50 estate agents suspected of trading without being registered receive regulator visits, HMRC has released updated money laundering guidance for the sector. https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment _data/file/799193/EAB.pdf Those operating in this industry are now required […]
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