This week the UK’s Financial Conduct Authority has looked into its crystal ball and published its “Business Plan 2015/16”. Whereas previous editions of this document were accompanied by a Risk Outlook, this time the two have been united into one plan which, according to the FCA, “will more clearly show how our analysis of risk is connected to our regulatory actions and how we seek to advance our objectives”. Everything that the FCA does is deeply fascinating, of course, but my AML-obsessed eye is drawn magnetically to the section of the plan that tackles financial crime.
Forewarned is forearmed, they say, and UK MLROs would do well to take note of the FCA’s declaration that “during 2015/16 we will continue to focus on both anti-money laundering (including terrorist financing and sanctions) and anti-bribery and corruption measures, as these are the areas in which we consider we can deliver the most value”. It’s a bit do-gooder-woolly, that word ‘value’, but I guess they mean it’s an area where they can have the most impact by challenging “the often poor anti-money laundering systems and controls we see in firms of all sizes”. In particular, the FCA tells us that they are “implementing an enhanced anti-money laundering supervision strategy, which includes continuing our Systematic Anti-Money Laundering Programme to assess AML (including counter terrorist financing and sanctions) and ABC [anti-bribery and corruption] controls at major firms”.
The FCA is also doing some renovations down at Canary Wharf, and “will bring together all of our second line risk functions to form a single risk and compliance division [which] will provide a strong, independent oversight of our activities and approach”. As we know, work is well underway on the senior managers’ regime, and the FCA says that its new rules “will make it easier for both firms and regulators to hold individuals to account, [because] increased individual accountability will improve behaviour, benefit consumers and markets, and can help restore public trust in banking”. The rules will be finalised by summer 2015 and brought into force by March 2016. And in case you’ve missed the significance of that, the FCA reminds us that “we will continue to focus our efforts on individual accountability in our enforcement work, and will continue to pursue appropriate cases against individuals”. As for how they learn about dodgy individuals, the FCA says with some satisfaction that “after seeing an increase in the number of whistleblowers who contacted us in 2014/15, and in the quality of information they gave us, we will continue our work on whistleblowing and will embed better arrangements and support for whistleblowers in the coming year”.