FCG 3.3 Further guidance

FCG 3.3.1

1FCTR contains the following additional AML guidance:

  1. FCTR 4 summarises the findings of, and consolidates good and poor practice from, the FSA’s thematic review of Automated Anti-Money Laundering Transaction Monitoring Systems

  2. FCTR 5 summarises the findings of, and consolidates good and poor practice from, the FSA’s Review of firms’ implementation of a risk-based approach to anti-money laundering (AML)

  3. FCTR 10 summarises the findings of the Small Firms Financial Crime Review. It contains guidance directed at small firms on:

    1. ◦ Regulatory/Legal obligations (FCTR 10.3.1G)

    2. ◦ Account opening procedures (FCTR 10.3.2G)

    3. ◦ Monitoring activity (FCTR 10.3.3G)

    4. ◦ Suspicious activity reporting (FCTR 10.3.4G)

    5. ◦ Records (FCTR 10.3.5G)

    6. ◦ Responsibilities and risk assessments (FCTR 10.3.7G)

  4. FCTR 12 summarises the findings of the FSA’s thematic review of Banks’ management of high money laundering risk situations. It includes guidance on:

    1. ◦ High risk customers and PEPs – AML policies and procedures (FCTR 12.3.2G)

    2. ◦ High risk customers and PEPs – Risk assessment (FCTR 12.3.3G)

    3. ◦ High risk customers and PEPs – Customer take-on (FCTR 12.3.4G)

    4. ◦ High risk customers and PEPs – Enhanced monitoring of high risk relationships (FCTR 12.3.5G)

    5. ◦ Correspondent banking – Risk assessment of respondent banks (FCTR 12.3.6G)

    6. ◦ Correspondent banking – Customer take-on (FCTR 12.3.7G)

    7. ◦ Correspondent banking – Ongoing monitoring of respondent accounts (FCTR 12.3.8G)

    8. ◦ Wire transfers – Paying banks (FCTR 12.3.9G)

    9. ◦ Wire transfers – Intermediary banks (FCTR 12.3.10G)

    10. ◦ Wire transfers – Beneficiary banks (FCTR 12.3.11G)

    11. ◦ Wire transfers – Implementation of SWIFT MT202COV (FCTR 12.3.12G)

FCG 3.3.2

1FCTR also summarises the findings of the following thematic reviews:

  1. FCTR 3: Review of private banks’ anti-money laundering systems and controls

  2. FCTR 7: Review of financial crime controls in offshore centres

  3. FCTR 15: Banks’ control of financial crime risks in trade finance (2013)