The FSA released its review of authorised firms’ compliance with the UK Financial Sanctions regime on 27th April. The headline conclusion makes concerning reading: “Our review has led us to conclude that there are inadequacies in firms’ systems and controls to reduce the risk of a breach of UK financial sanctions in all size of firms across all financial sectors.”
To provide some examples, the FSA report talks of serious confusion between AML due diligence and name-checking for sanctions purposes; of a lack of appreciation of the full extent of financial products and services implicated; and of firms that have policies but fail to make sure staff are aware of them or to provide training.
The inadequacies seem to exist – no surprise, really – in inverse proportion to the size of the firm, with smaller firms lacking the resources to understand and deal with the significant complexities of the sanctions regime.
See full Press Release.
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