Dawn Razavi

Our very own Claire Rees DipFCP, DipAML, Financial Crime Regulatory Specialist takes a closer look at the proposed FCA guidance for transaction monitoring in our recent blog: https://hubs.li/Q02z2DBj0 #AML #financialcrime #amlcompliance #FCA #TransactionMonitoring

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The three stages of laundering money are: 1. Placement: The ""dirty money"" or proceeds of crime is placed in the financial system; 2. Layering: Moving funds around financial services, with a view to further disguising the proceeds of crime; and 3. Integration: When the money launderers can withdraw the funds from the financial system and use this for seemingly ""legitimate"" activities. Click below for our online Anti-Money Laundering training course, with access to our Free Demo Course.... #AML #AntiMoneyLaundering #RQCGroup

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🚨  FCA fines Starling Bank £29M for Major Sanctions Failures 🚨 The FCA has fined Starling Bank £28,959,426 for serious failures in its financial crime controls, notably around sanctions compliance and onboarding high-risk customers during a voluntary requirement. 🔍 Key Issues: 1️⃣ Starling failed to stop onboarding 49,183 high-risk customers despite a VREQ (Voluntary Requirement) imposed in 2021 to prevent this. This comes on the heels of a similar fine against Coinbase earlier this year. 2️⃣ Sanctions Screening Failure: Between 2017 and 2023, Starling’s automated system only screened customers against a fraction of the required sanctions lists, posing a significant risk of enabling financial crime. One Designated Person managed to open an account as a result. The FCA labelled the bank's sanctions controls as "shockingly lax," with systems that screened customers just once every 14 days. 3️⃣ Risk Assessment Weakness: Starling’s firm-wide risk assessment failed to appropriately assess its sanctions risk. They rated the risk as low, not considering key high-risk factors such as payments from crypto-related platforms and multi-currency accounts. ⚖️ Fine Breakdown: 💹 £1M of the fine relates to onboarding high-risk customers. 💹 £28M is tied to severe sanctions screening failures, which the FCA deemed a breach of Principle 3, which requires a firm to take reasonable steps to ensure that it has organised its affairs responsibly and effectively, with adequate risk management systems. 📚 A must-read for compliance officers and financial crime professionals! #FinancialCrime #Sanctions #AML #Compliance #StarlingBank #FCAPenalty 🔗 Full FCA notice: https://lnkd.in/ewyw-5Dc

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The UK FCA's Financial Crime Guide is just a guide, it is not law or regulation; but it has been referred to in 44% of Final Notices issued by the FCA to firms for financial crime related failings in the last four years. Which is why we think it is worth taking note of these updates that the FCA proposes to make to the guide. #Investigations #FinancialCrime #FinancialServices

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Important tips and strategies to avoid being in a backlog situation!

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We're back with the second instalment of our Back to Basics blog series! ✍️ This week we explore the main roles of an AML Compliance Officer, and why implementing AML, KYC and due diligence measures are essential in securing the safety of your business.🔒 Have a read here: https://hubs.ly/Q02L50HG0

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AML NEWS: FCA imposes its largest #fine of this year. It has fined Starling Bank £29m for #financialcrime failings relating to its financial sanctions screening. The regulator's Joint Executive Director of Enforcement and Market Oversight, commented that "Starling’s financial sanction screening controls were shockingly lax. It left the financial system wide open to criminals and those subject to sanctions". The #regulator highlighted that this case took 14 months from opening to achieving an outcome. This compared to an average of 42 months for cases closed in 2023/24. Starling Bank's chairman said "we have invested heavily to put things right, including strengthening our board #governance and capabilities". #antifinancialcrime #AML #sanctions #compliance #eigerregulatorypartners https://lnkd.in/ejjd7CrR

I highly recommend trying ViCA for regulatory compliance support. It is not just any other AI tool.

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Have you completed your AML data questionnaire? If not, you now have 10 days to meet the deadline for completing the questionnaire, and if the number of questions we have had on some of the questions it is clear it is not something that can be done at the last minute, for example: 1. What percentage of your firm's new AML matters in the last 12 months had Enhanced Due Diligence applied to them? 2. How many clients have you acted for in the last 12 months who were a Politically Exposed Person excluding instances where the beneficial owner of a client was a PEP? 3. In the last 12 months, have you carried out any work for a sanctioned individual, organisation or ship or vessel? Unless you have been keeping very detailed records, gathering the required data is likely to take some time, so act now otherwise you could fail to meet the deadline and end up on the Solicitors Regulation Authority naughty step!

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Are you planning compliance and anti-financial crime training for 2025? 🚧 We are seeing an increased focus on the people and cultural aspects of compliance and anti-financial crime. These have prominently featured in recent high profile enforcement actions including TD Bank and Starling Bank, and regulators are likely to be looking more closely at how firms approach these in 2025. 🔎 I had the opportunity to briefly discuss the people side of fighting financial crime at a Transform Finance event last week in London and discussed how firms can actually start to change culture and conduct through the simplest of changes without spending more on their programmes. 💰 Why not check out our free and easy to read articles that practically explain some of the common challenges firms may encounter in compliance and anti-financial crime training and how to navigate them? No matter how big, small or complex your firm or programme it is 15 minutes well spent https://lnkd.in/eTtAj9Wf. ⏰ If you need any advice with your related programme, frameworks, methodology, training or in remediating past challenges in any jurisdiction, this is what we specialise in at ComplianceLnD. Email us at contact@compliancelnd.com for a free and confidential chat or visit us at www.compliancelnd.com. Fiona Hanlon Michael Kavanagh Deirdre McDonnell Dermot Kennedy MBA, BFRCP Andrew Quinn Ian Mynot Seán Wade Peter Kiernan Louie Vargas Sinead English Brian Weiss Samantha Martin-Woodgate Sinead Halhed-Moran Walsh Elliott Turner Jacquie Ryan, CFRCP James Treacy Stephen Rae Claire Schlag 

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Managing Financial Crime Risks: Lessons from Starling’s £29m Fine. On October 2nd 2024, Starling Bank was fined £29 million for serious failings in onboarding high-risk customers and sanctions screening over a four-year period (2019 to 2023). The Financial Conduct Authority (FCA) investigation exposed significant weaknesses in Starling’s control frameworks, highlighting the crucial importance of managing financial crime risks effectively. With nearly 50,000 high-risk accounts opened during this period, the fine serves as a stark reminder that inadequate systems and oversight can lead to costly consequences. For organisations looking to strengthen their financial crime risk management and ensure compliance, AJC provides expert guidance to help implement robust and reliable controls. Learn more: https://lnkd.in/engfu6sU #starlingbank #FinancialCrimeRisk #FinancialCompliance #RiskManagement #SanctionsScreening #AMLCompliance #FCARegulations #ComplianceMatters #BankingCompliance #FinancialControls #RiskMitigation #BusinessResilience #RegulatoryCompliance #AJC #ComplianceLeadership #LessonsInFinance

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Starling Bank was fined by the FCA for a sanctions breach due to poor systems and controls in monitoring financial crime. #financialcrime #aml #sanctions #antimoneylaundering #bankingsector #financialsector #fintech #complianceprofessional #complianceofficer #regulatoryaffairs

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🚨 Urgent update for firms involved with the sanctions regime 🚨 The Legal Services General Licence issued by the HM Treasury expires on 28 October 2024. HM Treasury may choose to renew it under the same terms or vary them, so affected firms should pay close attention to their website. For those firms holding frozen assets, the reporting deadline is on 11 November 2024. If this affects you, make sure those reports are submitted on time! Key actions for firms: • Review ongoing matters with sanctioned clients • Get ready for the new requirements after the licence ends • Cease services related to the expiring licence • Complete frozen asset reports by the deadline Missing these deadlines could result in serious penalties. Stay up-to-date with the latest OFSI and UK Gov guidance and be prepared. UK financial sanctions guidance: https://bit.ly/3YkJcqA Legal Services General Licence: https://bit.ly/3Abx6Io Reporting information to OFSI – what to do: https://bit.ly/3UlMDfL

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𝐀 𝐋𝐞𝐬𝐬𝐨𝐧 𝐢𝐧 𝐑𝐞𝐠𝐮𝐥𝐚𝐭𝐨𝐫𝐲 𝐂𝐨𝐦𝐦𝐢𝐭𝐦𝐞𝐧𝐭𝐬 Recently, Starling Bank was fined £29 million by the UK's Financial Conduct Authority (FCA) for failing to comply with previously agreed-upon requirements. The FCA found that Starling did not properly adhere to financial crime prevention measures, including screening for financial sanctions and managing high-risk customers. While designing a robust risk environment is a critical objective for every compliance department, this case clearly highlights that fulfilling commitments made to regulators is of utmost importance. Starling's fine emphasizes that 𝐚 𝐜𝐨𝐦𝐩𝐚𝐧𝐲'𝐬 𝐚𝐛𝐢𝐥𝐢𝐭𝐲 𝐭𝐨 𝐜𝐨𝐦𝐩𝐥𝐲 𝐰𝐢𝐭𝐡 𝐚𝐠𝐫𝐞𝐞𝐦𝐞𝐧𝐭𝐬 𝐦𝐚𝐝𝐞 𝐰𝐢𝐭𝐡 𝐫𝐞𝐠𝐮𝐥𝐚𝐭𝐨𝐫𝐲 𝐛𝐨𝐝𝐢𝐞𝐬 𝐢𝐬 𝐩𝐚𝐫𝐚𝐦𝐨𝐮𝐧𝐭. Key takeaways for businesses: 1) Compliance is a continuous process - Regularly review and update your systems and controls to meet regulatory expectations and avoid potential fines. 2) Risk assessments are essential - Frequently evaluate your risk exposure and adjust your AML program accordingly to maintain compliance. 3) Engage with regulators - Maintain open communication with regulatory authorities and demonstrate transparency in your financial crime prevention efforts. In the ever-evolving fintech landscape, businesses must prioritize adherence to their commitments and foster a strong compliance culture to prevent costly penalties and damage to their reputation. It's all about commitment! #fintech #fincrime #aml #screening #sanctions

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Financial Crime Partner, Jessica Cath, features in Citywire's article: FCA clamps down on platforms and advice firms for AML failings Jessica provides her expert insight on anti-money laundering (AML) systems and controls, that investment platforms AND advice firms using the platforms need to consider in light of the FCA's examinations. Click here to read the article: https://hubs.la/Q02-WwkK0 The FCA's AML focus on platforms and partnering advice firms has led to the issuing of voluntary requirement notices (VREQs) and fines across the industry, most notably to challenger banks Metro Bank and Starling Bank. If you are an investment platform or an adviser firm and would like to speak to one of our experts, please contact: - Thomas Dudley, Partner, Investment Platforms (tom.dudley@thistleinitiatives.co.uk), or - Jessica Cath, Partner, Financial Crime (jessica.cath@thistleinitiatives.co.uk) #AML #Platforms #IFA #FinancialAdvisers

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FCA Unveils New 5-year Strategy to Boost Trust in UK Market Financial Conduct Authority chief operating officer Emily Shepperd said tackling financial crime is one of four pillars of the new strategy. https://lnkd.in/dHMCBBj8

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The Financial Conduct Authority (FCA) has fined Metro Bank £16.7 million for failing to have adequate systems and controls to monitor #moneylaundering risks between June 2016 and December 2020. The bank's automated system, implemented in June 2016, did not function correctly, leading to unmonitored transactions. Despite junior staff raising concerns in 2017 and 2018, the issues were not addressed until December 2020. Metro Bank has since implemented remediation processes to fix these issues. #FinancialCrime #Compliance #AML #AntiMoneyLaundering #RegulatoryCompliance #RiskManagement #Banking https://lnkd.in/e7xJ9gCR

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