AML and Financial Crime
- Financial crime is one of the most significant global enforcement risks for firms – some of the FCA’s most significant fines in the past two years related to AML breaches.
- Common issues arising in enforcement cases include resourcing constraints and internal challenge; timeliness of CDD; weaknesses in automated processes to detect financial crime; inadequate policies and procedures; and adherence to UK requirements when relying on global centres of excellence or shared service providers.
- Continued FCA emphasis on a more integrated approach to managing financial crime risks, including anti-bribery and corruption, and the use of more sophisticated surveillance and data.
- Fintechs and challengers responsible for much of the growth in DAML SARs filings. Their innovation and new tech may make them targets; they should grow and adapt their financial crime controls as their businesses develop.
247% increase in DAML SARs filed by fintechs*
52% of all DAML SARs are now filed by fintechs*
*UKFIU reporting year 2019-20