Claims Management Companies (CMC) Compliance Procedures and Financial Crime Policy

regulatory compliance risk management reputation
Original Post: 12th April 2019. Updated: 7th August 2019.

Claims Management Companies will need to provide to the FCA, when and if asked, Compliance Procedures and Financial Crime policies.

We have worked with a number of CMCs and have created the following for your use.


Compliance Procedures Manual – Around 92 pages

1. Introduction
2. Your responsibility
3. Regulatory environment and scope of permissions
4. Principles for Senior Managers & Certification Regime SMCR) for FCA regulated firms
5. The Company’s Compliance Structure
6. Money Laundering
7. Senior management arrangements, systems and controls
8. Conflict of Interests
9. Dealing with Customers
10. Financial Promotions
11. Customer Complaints
12. Training and Competence
13. Outsourcing
14. Notifications to FCA
15. Breach, Discipline and Enforcement
16. Compliance Monitoring
17. Data Protection
Appendix A – Complaints Logs Frameworks
Appendix B Bibliography
  • Compliance Oversight and the Compliance Function
  • Claims Management Conduct of Business Sourcebook and Client Assets
  • Regulatory Approach to Risk Management
  • Compliance and Ethics
  • Anti-Money Laundering
Appendix C GDPR Compliance Statement Template

Financial Crime Policy – Around 16 pages

1 Introduction To Financial Crime Policy
Appendix 1: Register of Attendees

All this from professional compliance consultants for just £450!


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