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“We are disappointed with the disclosure results with only 52.9% of sampled cases providing acceptable disclosure …….. further work is required by the sector”
The FCA stated in their report on “Suitability” in May that “We are disappointed with the disclosure results with only 52.9% of sampled cases providing acceptable disclosure and further work is required by the sector to improve the initial disclosure (includes firm’s costs and services).”
Having met with the FCA Supervision Team (authors of the report) recently we have a good handle on what they mean and what they hoped to see already in place.
Additionally there was also a great deal of discussion around the suitability letter construction and what content should be included.
Regarding the Senior Managers & Certification Regime, (https://www.fca.org.uk/firms/senior-managers-certification-regime/solo-regulated-firms) we have already worked on this for banking groups and know what is involved, the final tweaks are awaited but
In the details released on 26th July 2017, the FCA said the requirements will include “responsibilities maps, handover procedures, and will need to make sure that there is a senior manager responsible for every area of their firm”.
This means that your procedures need to be identified, mapped and recorded with owners and relevant controls.
What We Are Offering
To Help You Ensure You Are Comfortable With Your Compliance Affairs, We Have Two Offers;
5 Days Work for the price of 4
If you have a piece of work that needs doing, we will arrange to provide 5 days service either at your work site or from a distance (typically report writing etc) at a 20% Discount if at least 5 days work is booked.
What Does This Mean?
This means simply whereby we would normally charge in the range of £650 to £850 for a days’ consultancy work, over a week that would be £3,250 to £4,250 – with our offer that is reduced to £2,600 to £3,400 and no VAT!
As An Extra
We Operate A “Benchmarking Audit” and that is on special offer until 4th August from £2,600 discounted to £2,080 with no VAT!
We can offer these discount ONLY FOR WORK BOOKED IN BY
5.00pm 4th AUGUST 2017
CLICK HERE to register your interest and get a copy of our
“Suitability Guide” absolutely Free!
We list some companies that may be worth trying below, but have no connection with them or receive any benefit from them at all.
We wish you the very best of luck with your future!
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A compliance definition is difficult to obtain other than “We define compliance within our firm as the function of identifying relevant legislative, regulatory and best practice requirements and then implementing the required changes to our systems and controls to facilitate adherence to these obligations on an ongoing basis.”
However, every firm needs external perspective and Compliance Consultant – as a leading regulatory compliance specialist consultancy have many different and adaptable services to offer.
The final two pieces of UK legislation implementing MiFID II were laid before Parliament on 26th June which give the FCA powers to make certain of the changes to the handbook rules (such as the financial promotion rules) and to carry out certain administrative tasks linked to implementation (such as setting position limits).
These are the:
Data Reporting Services Provider Regulations http://www.legislation.gov.uk/id/uksi/2017/699
Markets in Financial Instruments Regulations http://www.legislation.gov.uk/id/uksi/2017/701
With that in mind, I thought I would just remind you of what’s happened and what’s on the radar that you may need some assistance with the planning and implementation of.
See Our Special Offers At The Foot Of This Article
Save Money On Your AML Manual & Governance Review!
These areas are;
Questions to ask
Do we as a company understand;
These issues will not be changing any more, if these are not addressed immediately by firms spending a little money now, they are going to be spending absolute fortunes at the last minute. All firms will have to demonstrate “on demand” that they have everything in place.
You may find these links useful http://www.complianceconsultant.org/so-remarkably-simple-yet-detailed-and-thorough-compliance-risk-management-reference-system/ and https://www.linkedin.com/pulse/do-you-know-how-impacted-lee-werrell
Any firms that may need assistance with any of these areas can contact us for support on 0203 815 7939. Please be aware that our resources are limited and bookings for this work are already being placed. Depending on the size of your project, discounts of up to 20% are available.
If you would like any further information, please drop me a line.
Special Offers For Limited Number And/Or Date
If you want to get an up-to-date AML & CTF Manual, with 1/3rd Off please click on this link (http://aml-compliance-manual-ofac-sanctions-ctf.co.uk) and use the code “CCMLD4” in the payment box for a full 1/3rd discount! Hurry because this only valid for the first 25!
If you want to take advantage of our policy checking offer, go to our special offer at http://www.complianceconsultant.org/product/regulatory-changes-will-force-governance-reviews but hurry, this is only on sale until the 21st July!
On the 15th March 2017, the UK Government announced the creation of a new watchdog for anti-money laundering.
Named the Office for Professional Body Anti-Money Laundering Supervision (OPBAS), it aims to tackle the methods of financial criminals by both stepping up standards of anti-money laundering (AML) supervision and closing loopholes in guidance that can be exploited to move illicit funds.
The UK Government’s ‘Action Plan for Anti-Money Laundering and Counter-Terrorist Financing’, released in April 2016, included an objective to review and improve the effectiveness of AML and CTF supervision. Subsequently, between April and June 2016, HM Treasury undertook a review of the UK AML / CTF supervisory regime. The review involved an audit of the FCA, Serious Fraud Office (SFO), HM Revenue and Customs (HMRC) and the National Crime Agency (NCA).
A key theme running through the review was a lack of consistency and potential confusion caused by the number of supervisory bodies overseeing firms’ activity in this area. It also referred to the guidance provided by legal and accounting firms, which is sometimes conflicting in its message.
All of this has the potential to create loopholes that criminals can exploit – as such there is a need to seek a more consistent approach to both supervision and guidance. OPBAS will seek to better unify the various industry, regulatory and legislative approaches.
OPBAS will have overall responsibility for the various supervisory organisations involved to ensure consistency of approach.
It will also set out how these bodies can comply with supervisory standards once they are updated to incorporate requirements of the EU’s 4th Anti-Money Laundering Directive (4AMLD), due to be implemented by the UK on the 26th July 2017.
More specifically, OPBAS’s objectives are to:
OPBAS is due to be legislated for by the end of this year and operational from the start of 2018, and we can anticipate new guidance to be released shortly after this.
OPBAS will become operational several months after the updated money laundering regulations are implemented, but firms will not want to wait until this time to make sure they are compliant.
The new office will sit within the FCA and operate in line with its existing governance structure. AML supervision is already an area of strong focus for regulators and was earmarked as a priority by the FCA in its 2016 / 17 Business Plan as it looked to broaden its Systematic Anti-Money Laundering Programme (SAMLP). This focus will increase into 2017 / 18.
Not only is the focus increasing in terms of regulatory output; the level of insight FCA receives back on these issues continues to increase with the implementation of REP-CRIM financial crime reporting in January 2017. This extra insight being gained by regulators will serve to enhance their view – this may manifest itself in further changes to supervision, and firms will need to continue to keep abreast of any developments.
The creation of OPBAS will mean increased scrutiny of professional AML supervisory bodies in terms of how they supervise AML and CTF compliance. This will create a knock-on effect for firms themselves, which could quickly feel the effects of this closer supervision. Following some uncertainty in terms of AML guidance from a supervisory point of view, the intention of regulators will be to ensure enforcement action is taken should deficiencies be identified – this has been a well-documented challenge in the current regulatory environment.
With the Government response on how money laundering regulations will be incorporated due in April, supervisory bodies may arguably be left with little time to interpret the regulations and revise their rules and guidance for firms in time for the 26th July and 4AMLD. This could in turn challenge firms’ ability to prepare for the changes. Staying abreast of developments in this space with the aim of prompt but proportionate action (when appropriate) should be firms’ current focus.
To help with your Anti-Money Laundering procedures as well as other Compliance support services, please contact us on 0203 815 7939
The majority of compliance consultancy services are found in London due to the high concentration of financial services firms being located there. Compliance Consultant is no exception, and we have our London office located just outside the City of London, within easy walking distance of most of our major clients. Additionally we have an office on the South Coast, which handles most of the provincial business, from Falmouth to Edinburgh and Belfast to Dover, criss-crossing the UK, to provide a value based service to all clients.
The range of services we offer can vary with the type of client from small Electronic Money Institutions to new banking licences, from Independent Financial Advisers (IFAs) through to Insurance Companies and Payment Institutions, we have a range of products to suit.
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If you need a Compliance Consultancy London, or indeed, Compliance Consultants uk (as we operate countrywide and even in Europe and the gulf region), then call us on 0203 815 7939 or email email@example.com