The importance of purposeful anti-money laundering controls

Apr 1st '21

Speech by Mark Steward, Financial Conduct Authority (FCA) Executive Director of Enforcement and Market Oversight, delivered at the AML & ABC Forum 2021.


  • Two of the biggest sanctions in the last 12 months related to failures to address financial crime and anti-money laundering (AML) risks.
  • The FCA currently have 42 investigations ongoing into firms and individuals involving, for example, systems and controls over politically exposed persons, customers with significant cash intensive operations, correspondent banking and trade finance, and transaction monitoring.
  • AML investigations are often complex because they are rarely transactional and require a systemic understanding of how a firm operates, its governance controls, its cultural habits, and the nuts and bolts of sometimes opaque systems.
  • In the last 12 months, the FCA have increased surveillance of online investment promotions targeting offers from unauthorised firms, potential investment scams and other too good to be true promotions, including lead generation sites.


To read the speech in full, click here.


Source: FCA


About us

At LS Consultancy, our consultants are industry experts that interpret the rules, regulations and spirit of the industry guidelines by assisting you “the client” in implementing a compliance programme that you can be confident is mitigating the risk of financial crime. What we can do:


  • We analyse the relevant jurisdictions legislation, regulation and industry guidance to ensure that your controls adopt the highest standard possible
  • Analyse and/ or Enhance your Business Wide Risk Assessment to ensure we consider money laundering and relevant predicate crimes
  • Assessment of your Customer Onboarding and/ or Periodic KYC reviews rely on independent documentation and supported by credible information from your customer – as this is key to your compliance programme.
  • Robust Transaction Monitoring and Screening whilst utilising your up-to-date KYC documentation/ information are fundamental.
  • Greater emphasis on training – why not go through live examples with your RM’s, Operational Teams and Compliance – discuss the areas of concern and come up with compliant solutions.
  • Ensuring your Compliance Monitoring Programme is conducted on a regular basis
  • Engagement with senior management through relevant committees


For further information please contact us where our industry experts will be happy to answer your questions.


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