Thematic examinations scheduled for early 2021

Early next year we will be publishing our programme of thematic examinations for 2021. Ahead of that, we wanted to give you advanced notice of two thematic examinations that we will be undertaking in the New Year.

Enhanced due diligence and simplified due diligence

During 2016 and 2017, we conducted a thematic examination on Enhanced Due Diligence Measures (EDD) and Simplified Due Diligence Measures (SDD). Following the examination, we shared a summary of our findings.

Themed Examination Programme: enhanced and simplified due diligence

In the first quarter of 2021, our Supervision Examination Unit will undertake a further examination to see how firms are applying these measures to business relationships. This examination will focus on when and how Relevant Persons have applied EDD measures to a business relationship, where they have identified and assessed that there are higher risks of financial crime. It will also assess how firms apply exemptions and simplified approaches to identification measures, if they’re satisfied that the customer qualifies for exemptions and there is little risk of financial crime.

We will contact businesses to notify them in advance if they are selected for this examination.

Wire transfers

Since postponing the wire transfers thematic review scheduled for this year due to Covid, we have now issued a questionnaire to 19 banks. This questionnaire is intended to identify, assess and mitigate any risks posed by wire transfer activity; specifically those aspects that reflect FATF Recommendation 16. 

We will conduct a number of more in depth examinations in early 2021.