On 25 April 2024, the Financial Conduct Authority (FCA) published Consultation Paper CP24/9 on proposed changes to its Financial Crime Guide (the Guide).
The proposed updates relate to sanctions, proliferation financing and transaction monitoring. In addition, the FCA is proposing to add references to cryptoassets and the Consumer Duty, along with consequential changes throughout the Guide. The FCA’s aims in making these changes are to help firms understand its expectations, to help firms assess the adequacy of their financial crime systems and controls, and to remedy deficiencies. The Guide contains self-evaluation questions and examples of good and poor practice for firms drawn from FCA work and other financial crime publications.
Proposed changes
The changes proposed in CP24/9 include:
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Sanctions: The FCA proposes to update this section of the Guide to reflect what it and firms have learned from the extensive assessments carried out of firms’ sanctions systems and controls foll