FCG 1.3 Format of the FCG

Financial crime: a guide for firms

FCG 1.3.1

1FCG looks at key aspects of firms’ efforts to counter different types of crime. It is aimed at firms big and small; material will not necessarily apply to all situations. If guidance is specific to certain types of firm, this is indicated by italics.

Self-assessment questions:

  1. • These questions will help you to consider whether your firm’s approach is appropriate. (Text in brackets expands on this.)

  2. • The FCA may follow similar lines of inquiry when discussing financial crime issues with firms.

  3. • The questions draw attention to some of the key points firms should consider when deciding how to address a financial crime issue or comply with a financial crime requirement.

  4. Examples of good practice

    Examples of poor practice

    This list provides illustrative examples of good practices.

    This list provides illustrative examples of poor practices.

    Good practice examples are drawn from conduct seen in firms during thematic work in relation to financial crime.

    Poor practice examples are also drawn from conduct seen during thematic work.

    We would draw comfort from seeing evidence that these practices take place.

    Some show a lack of commitment, others fall short of our expectations; some, as indicated in the text, may breach regulatory requirements or be criminal offences.

    Note that if these practices are lacking it may not be a problem. The FCA would consider whether a firm has taken other measures to meet its obligations.

    These do not identify all cases where conduct may give rise to regulatory breaches or criminal offences.

Case studies and other information

FCG 1.3.2

1Most sections contain case studies outlining occasions when a person’s conduct fell short of the regulatory expectations, and enforcement action followed; or information on topics relevant to the section.