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  • Read our 2023 examination feedback on terrorist financing and proliferation financing
Industry update 03 October 2024
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Read our 2023 examination feedback on terrorist financing and proliferation financing

In 2023, 43 supervised persons across seven industry sectors completed a questionnaire on terrorist financing (TF) and proliferation financing (PF).

Topics included:

  • corporate governance
  • internal systems and controls
  • customer risk assessments
  • screening of customers and activity
  • reporting of TF/PF
  • asset-freezes and related licences
  • training and awareness of employees

Following the questionnaire, a sample of six supervised persons were selected for an onsite examination. The selection process was determined by supervisory risk data available to us.

Our onsite examinations and questionnaire responses identified deficiencies across the following areas:

  • corporate governance
  • customer risk assessments
  • customer due diligence measures
  • enhanced customer due diligence
  • internal systems and controls (including policies and procedures)
  • suspicious activity reporting and sanctions reporting
  • awareness and training of employees
  • record-keeping

Next steps

All supervised persons who received and completed a questionnaire, and all examined supervised persons have received direct feedback from us. Where findings were identified, the supervised persons were required to submit a formal remediation plan setting out actions to be taken and timescales for completion.

Supervised persons should consider the findings and good practice identified in this feedback paper against their own arrangements.

Read our full feedback paper for detailed findings and good practice: 2023 countering the financing of terrorism and proliferation financing examination feedback

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