Emma RadmoreIn the light of the tranche of sanctions imposed on Russia, FCA has reminded firms it expects them to have established systems and controls to counter the risk they they might be used to further financial crime, and that both it and OFSI have power to take action against firms that do not comply (or, in FCA’s case, have appropriate systems and controls to comply) with sanctions.
FCA reminds firms of where it has set out its expectations (including its Dear CEO letter from September 2021 to trade finance firms), and also that if transactions give rise to suspicions of sanctions evasion or money laundering they should consider whether a SAR to the NCA is needed.
