FCG 1.3 Format of the FCG

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.

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.