On 6 May 2020, the FCA published a new web page, Financial crime systems and controls during coronavirus situation.
Key messages on the web page include:
- it is important that firms remain vigilant to new types of fraud and amend their control environment where necessary to respond to new threats. This should include the timely reporting of Suspicious Activity Reports of any new threats;
- the FCA recognises that, while continuing to operate within the legislative framework for anti-money laundering and counter terrorist financing, firms may need to re-prioritise or reasonably delay some activities. These could include ongoing customer due diligence reviews, or reviews of transaction monitoring alerts. The FCA will consider such delays reasonable as long as: (i) the firm does so on a risk basis (for example, reviews for high risk customers should not be delayed unless absolutely necessary); and (ii) there is a clear plan to return to the business as usual review process as soon as reasonably possible;
- where firms need to amend their controls in response to the current circumstances, decisions should be clearly risk assessed, documented and go through appropriate governance;
- the FCA expects firms to notify it of any material issues that are impacting the effectiveness of their financial crime controls or causing significant delays to remediation plans; and
- firms should continue to comply with their obligations on client identity verification. The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 and Joint Money Laundering Steering Group guidance already provide for client identity verification to be carried out remotely and give indications of appropriate safeguards and additional checks which firms can use to assist with verification.