FCG 2.3 Further guidance

1FCTR contains the following additional guidance on governance:

1. • FCTR 6.3.1G (Governance), from the FSA’s thematic review Data security in Financial Services

2. • FCTR 8.3.1G (Senior management responsibility) from the FSA’s thematic review Financial services firms’ approach to UK financial sanctions

3. • FCTR 9.3.1G (Governance and management information) from the FSA’s thematic review Anti-bribery and corruption in commercial insurance broking

4. • FCTR 11.3.1G (Governance, culture and information sharing) from the FSA’s thematic review Mortgage fraud against lenders

1FCTR contains the following additional guidance on risk assessment:

1. • FCTR 8.3.2G (Risk assessment) from the FSA’s thematic review Financial services firms’ approach to UK financial sanctions

2. • FCTR 9.3.2G (Risk assessment and responses to significant bribery and corruption events) from the FSA’s thematic review Anti-bribery and corruption in commercial insurance broking

3. • FCTR 10.3.7G (Responsibilities and risk assessments) from the FSA’s thematic review The Small Firms Financial Crime Review

4. • FCTR 12.3.3G (High risk customers and PEPs – Risk assessment) and (Correspondent banking – Risk assessment of respondent banks) from the FSA’s thematic review Banks’ management of high money laundering risk situations

1FCTR contains the following additional guidance on policies and procedures:

1. • FCTR 8.3.3G (Policies and procedures) from the FSA’s thematic review Financial services firms’ approach to UK financial sanctions

2. • FCTR 10.3.1G (Regulatory/Legal obligations) from the FSA’s thematic review The Small Firms Financial Crime Review

3. • FCTR 12.3.2G (High risk customers and PEPs – AML policies and procedures) from the FSA’s thematic review Banks’ management of high money laundering risk situations

1FCTR contains the following additional guidance on staff recruitment, vetting, training and awareness:

1. • FCTR 6.3.2G (Training and awareness) and FCTR 6.3.3G (Staff recruitment and vetting) from the FSA’s thematic review Data security in Financial Services

2. • FCTR 8.3.4G (Staff training and awareness) from the FSA’s thematic review Financial services firms’ approach to UK financial sanctions

3. • FCTR 9.3.5G (Staff recruitment and vetting) and FCTR 9.3.6G (Training and awareness) from the FSA’s thematic review Anti-bribery and corruption in commercial insurance broking

4. • FCTR 10.3.6G (Training) from the FSA’s thematic review The Small Firms Financial Crime Review

5. • FCTR 11.3.6G (Staff recruitment and vetting) and FCTR 11.3.8G (Staff training and awareness) from the FSA’s thematic review Mortgage fraud against lenders laundering risk situations

1FCTR contains the following additional guidance on quality of oversight:

1. • FCTR 6.3.15G (Internal audit and compliance monitoring) from the FSA’s thematic review Data security in Financial Services

2. • FCTR 9.3.9G (The role of compliance and internal audit) from the FSA’s thematic review Anti-bribery and corruption in commercial insurance broking

3. • FCTR 11.3.5G (Compliance and internal audit) from the FSA’s thematic review Mortgage fraud against lenders

1 For firms’ obligations in relation to whistleblowers see the Public Interest Disclosure Act 1998: www.legislation.gov.uk/ukpga/1998/23/contents