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 […]

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 […]

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 […]

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 […]

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 […]

On 8 May 2019, the Central Bank of Ireland found Campbell O’Connor & Company, a private client stockbroker, guilty of five breaches of the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010 (CJA 2010) between July 2010 and November 2016. These breaches comprised of failings in the firm’s anti-money laundering and combating the financing […]

The Jersey Financial Services Commission (JFSC) has received top ratings for its trust company regulation following the first evaluation of its kind by the Group of International Finance Centre Supervisors (GIFCS). The GIFCS assessors visited the JFSC from 30 October to 3 November 2017 to conduct their review. Jersey was the first international finance centre […]

Summary What Next? Driving dirty money out of the UK financial system has become an increasing priority for the FCA, reflecting the higher profile which money laundering now has in the UK. This profile stems from a variety of sources, including the political focus on tackling the proceeds of crime, media investigations into tax evasion […]