FCG 1.3 Format of the FCG
Financial crime: a guide for firms
1FCG looks at key aspects of firms’ efforts to counter different types of crime. It is aimed at firms big and small; material will not necessarily apply to all situations. If guidance is specific to certain types of firm, this is indicated by italics.
Self-assessment questions:
• These questions will help you to consider whether your firm’s approach is appropriate. (Text in brackets expands on this.)
• The FCA may follow similar lines of inquiry when discussing financial crime issues with firms.
• The questions draw attention to some of the key points firms should consider when deciding how to address a financial crime issue or comply with a financial crime requirement.
Examples of good practice |
Examples of poor practice |
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This list provides illustrative examples of good practices. |
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This list provides illustrative examples of poor practices. |
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Good practice examples are drawn from conduct seen in firms during thematic work in relation to financial crime. |
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Poor practice examples are also drawn from conduct seen during thematic work. |
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We would draw comfort from seeing evidence that these practices take place. |
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Some show a lack of commitment, others fall short of our expectations; some, as indicated in the text, may breach regulatory requirements or be criminal offences. |
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Note that if these practices are lacking it may not be a problem. The FCA would consider whether a firm has taken other measures to meet its obligations. |
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These do not identify all cases where conduct may give rise to regulatory breaches or criminal offences. |
Case studies and other information
1Most sections contain case studies outlining occasions when a person’s conduct fell short of the regulatory expectations, and enforcement action followed; or information on topics relevant to the section.