As the regulatory world becomes more global in its approach, so we see increasing similarities between the priorities of our own domestic regulators in the US, and the Financial Conduct Authority (“FCA”) in the United Kingdom (“UK”). In their Annual Business Plan for 2015, the FCA announced key work streams and priorities that are quite similar to the US counterparts.
In other words, regulators across the globe are focused on unaffordable debt, financial firm culture or “tone at the top”, conflict of interest issues between the firm and their clients, contracts of adhesion or undisclosed terms, poor controls and risky products threatening market integrity, the failure on the part of firms to invest in compliance controls and technology, and cyber-security issues.
In addition to the above, the passing of the EU’s Fourth Money Laundering Directive presents new challenges for firm’s to address their internal controls. Enhanced due diligence for politically exposed persons (“PEPs”), increasing transparency regarding beneficial ownership of companies and trusts and increased criminal sanctions have placed additional scrutiny on Money Laundering Reporting Officers (“MLROs”) and firms to institute more rigorous controls.
At Alexander Church, we work with a wide array of experts and analysts who can assist your firm in the brave new world of UK Regulation. For more information, go to www.alexanderchurch.com or call our London office at 44 020 8798 0056