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Created with Fabric.js 1.4.5 Inadequate resources Controls failed to manage B&C risk Narrow B&C risk assessments Reputación Improved hospitality and training Inadequate client files Ubicua Weak senior management oversight FCA finds small firms need to manage financial crime risks more effectively Significant and widespread weaknesses in most banks anti-money laundering systems and controls TR14/17 Bribery and corruption in insurance intermediaries Slow response to AML reviews UK requirements Real vs Ficticio TR14/16 AML systems in small banks(who failed to respond to 2011 AML report) FCA RESPONSE FORENSICS RESPONSE Por Claudia E. Huerta Guzmán@clau_ehg Matt Russell has been working with FS Centre of Excellence on response to the Consultation Paper.Tola Johnson is progressing our thinking in ABC for the FS arena. Culture/governanceSenior management need to be more engaged and have better oversight. Management InformationSenior management need to have relevant MI to manage money laundering risk adequately. Weak knowledge of ML risks Culture/governance- Senior management oversight - Appropriate governance, clear risk appetite- Strong AML culture, tailored training- Branches/subs to consider local rulesManagement Information- Regular MI- Relevant MI (legal and regulatory developments, emerging trends or changes in risk assessments, overview of firm's financial system and controls) Updated guidance on Financial crime Source:
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