FCG 7.3 Further guidance

1FCTR contains the following additional material on sanctions and assets freezes:

1. • FCTR 8 summarises the findings of the FCA’s thematic review of financial2 services firms’ approach to UK financial sanctions and includes guidance on:

   1. ◦ Senior management responsibility (FCTR 8.3.1G)

   2. ◦ Risk assessment (FCTR 8.3.2G)

   3. ◦ Policies and procedures (FCTR 8.3.3G)

   4. ◦ Staff training and awareness (FCTR 8.3.4G)

   5. ◦ Screening during client take-on (FCTR 8.3.5G)

   6. ◦ Ongoing screening (FCTR 8.3.6G)

   7. ◦ Treatment of potential target matches (FCTR 8.3.7G)

2. • FCTR 15 summarises the findings of the FCA’s thematic review Banks’ management of financial crime risk in trade finance and includes guidance on:

   1. ◦ Sanctions Procedures (FCTR 15.3.7G)

   2. ◦ Dual-Use Goods (FCTR 15.3.8G)