The FCA recently issued a Dear CEO letter referring to firms being able to take a more flexible approach but in the same letter reiterated that the requirements of the Money Laundering Regulations 2017 still need to be complied with fully.
Given the FCA's focus on both regulatory investigations and criminal prosecutions for AML failings, and the desire of other UK and overseas prosecuting agencies to take action in this space, it is key that firms and their senior management make the right decisions.
Listen to our on-demand webinar current approaches to customer onboarding in a remote environment, during which we discuss:
If you need any further support on these issues, please contact Michael Ruck.
Michael supports clients on sensitive reputational matters, financial crime related issues and investigations. He previously spent four and a half years at another City law firm in the corporate crime, investigations and enforcement team and before that spent almost six years working in the FCA's Enforcement and Market Oversight Division. Michael has a broad range of experience including advisory, regulatory liaison and large-scale, complex multi-jurisdictional investigations. He has led financial services regulatory projects, investigations and proceedings for a range of institutions. His experience spans various regulatory issues and he has worked closely with a number of UK and foreign regulators, including the FCA, SFO, ICO, DOJ and IRS.
Davinia is a solicitor in TLT's Financial Services Regulation team. In addition to her expertise in insurance law, Davinia has experience of assisting financial services clients with customer journeys, financial crime policy and procedures, and conduct of business requirements. Prior to her legal career, Davinia was a compliance officer for an international insurance company. Over the course of her seven year insurance career, Davinia gained her Lloyd's and London Market Introductory Test (LLMIT) certificate, as well as qualifications in risk management.
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