146 findings identified in 2021 financial crime examinations
In 2021, we carried out 25 financial crime examinations, which identified 146 findings at the businesses we visited.
The 146 findings from our 2021 financial crime examinations were similar in nature to those outlined in our previously published feedback and related in the most part to statutory and regulatory requirements concerning:
- corporate governance
- customer due diligence measures
- reporting suspicions of money laundering and terrorist financing
- employee screening, awareness and training
Corporate governance arrangements relating to the roles of the Money Laundering Compliance Officer and the Money Laundering Reporting Officer and reporting suspicions of money laundering or terrorist financing featured prominently in examination findings for a second consecutive year, with 52 findings raised concerning non-compliance or partial non-compliance with relevant statutory and regulatory requirements.
We expect boards and senior management of supervised persons to consider the findings highlighted in this paper against their own arrangements to ensure their business is complying with relevant statutory and regulatory requirements.
Where supervised persons identify any deficiencies in systems and controls, we expect them to:
- prepare a remediation plan and discuss this with their supervisor
- consider the notification requirements under the AML/CFT Codes of Practice within Section 2.3 of the Handbook and Principle 6 of the relevant Codes of Practice
- remedy any identified matters in the manner identified in the documented remediation plan agreed with their supervisor
- consider what assurance activities will provide comfort to the board/senior management that deficiencies identified have been addressed effectively