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Financial Crime

Tackling financial crime is a high priority for regulators around the world, not least for the UK’s FCA. As the regulatory spotlight intensifies, so does the burden on financial services firms.

The implementation into UK law of The Money Laundering Regulation 2017, and its recent amendments in 2019, and the revised guidance from the Joint Money Laundering Steering Group (JMLSG) guidance have increased the pressure on businesses to do more about countering financial crime.

Keeping up with this constantly evolving picture can be challenging, but firms that fail to implement appropriate financial crime prevention measures in line with the latest regulations risk severe penalties and heavy fines.

Our financial crime team has the experience and expertise to provide effective support for your firm’s anti-money laundering (AML) and counter-terrorist financing (CTF) framework. We can also help with compliance advice, reports, audits, training and on-site support.

Anti-money laundering and counter-terrorist financing

Money laundering regulations for UK financial institutions have been in place since 1993. These have evolved over the years and are currently embodied in the Money Laundering Regulations 2017 as amended with effect from 2019.

Not all firms fall within the scope of the UK’s anti-money laundering (AML) regulations, but all firms must adhere to the Proceeds of Crime Act 2002 (POCA) and the Terrorism Act 2000.

It’s essential you ensure your firm plays its part in combatting money laundering and terrorist financing by adopting appropriate safeguards. Implementing adequate controls, systems and governance can save your firm from falling victim to money laundering and/or terrorist financing.

Our dedicated Financial Crime team can help you devise and implement proportionate risk-based procedures and AML/CTF policies that comply fully with the latest anti-money laundering regulations, industry guidance and FCA expectations.

Among firms required to demonstrate proportionate AML/CTF controls are:

      • Credit institutions
      • Financial institutions
      • Cryptoassest firms
      • Custodian wallet providers
      • Auditors, insolvency practitioners, external accountants and tax advisers
      • Trust or company service providers
      • Estate agents and letting agents
      • High-value dealers
      • Art market participants
      • Casinos
      • Independent legal professionals.

The members of our expert team hold ICA and CISI qualifications in Anti-Money Laundering. They offer a bespoke service to match your firm’s precise requirements in line with MLR (Amendments) 2019, POCA 2002, the Terrorism Act 2000, and the Bribery Act 2010.

Among the key areas you need to have addressed are:

    • AML/CTF policy
    • Due diligence procedures
    • Business risk assessment
    • Client risk assessment
    • Governance
    • Training
    • Record management
    • Reporting to external authorities.

Bribery and corruption

The Bribery Act 2010 and subsequent Ministry of Justice guidance require firms to have adequate procedures in place to prevent bribery and to take a risk-based approach to their exposure to bribery and corruption. Are you fully aware of your firm’s vulnerability to accepting and/or giving a bribe or becoming entangled in a corruption ring?

In line with the HMRC Bribery Act and the Ministry of Justice guidance, we can help you develop and implement proportionate anti-bribery and corruption policies and procedures and provide training that includes real scenarios involving bribery and corruption.

We can also help you ensure you have the appropriate gifts and hospitality and remuneration policies and register to meet the requirements of your firms risk exposure.

Tax evasion

The introduction of the Criminal Finances Act 2017 requires firms to implement controls to prevent employees and other associated parties facilitating tax evasion in the UK or overseas. Understanding exactly what’s required to meet this legal requirement can be complicated.

Our Financial Crime team can provide live training sessions to explain precisely what the legislation requires of your firm and to give you the reassurance of knowing that your employees understand their legal responsibility in relation to tax evasion. We can also help you establish a risk-based approach to tax evasion prevention, based on current industry guidance, and ensure your firm has understood where within your business tax evasion could occur.

Fraud

Fraud costs the UK economy around £200bn a year. Private-sector firms, ranging from SMEs to major enterprises, bear the brunt of rising levels of fraudulent activity. But far too many still lack adequate procedures for mitigating fraud risk. Are you confident your firm fully understands the various types of fraud you could be exposed to?

Better-known categories of fraud include identity fraud, mail fraud and credit/debit card fraud. But as technology comes to play an ever more central role in the financial services sector, so the financial crime that follows in its footsteps becomes increasingly sophisticated. We can help you and your employees understand the many guises in which fraud may present itself, and how best to safeguard your firm and its customers. We can also help you implement strong fraud policies and procedures to mitigate the risks associated with fraud.

Our expert team can apply their detailed knowledge of regulation, industry best practice, and financial crime risk to create practical and tailored solutions to your firm.

For more information about our financial crime and anti-money laundering services, call 0207 436 0630 to speak to one of the members of our team or email info@thistleinitiatives.co.uk.


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