10th February 2015

BBA response to FCA consultation- proposed guidance on financial crime systems and controls (GC14/7)

BBA members are highly committed to tackling financial crime. Firms closely examine the FCA financial crime guide to ensure that systems and controls are updated to reflect evolving regulatory expectations. The BBA is therefore pleased to respond to consultation GC 14/7 on behalf of the banking industry.

The banking industry has welcomed the useful dialogue with the FCA on AML/CTF and sanctions compliance matters over recent months. We hope to continue the constructive discussions on the proposed changes to the FCA Guidance in particular around Source of Wealth and Source of Funds.

We note that the 4th EU Money Laundering Directive is now finalised and EU Guidelines will now be developed. We will be working with our members to consider how resources can be best deployed to meet the FCA expectations and the new EU requirements, whilst prioritising efforts against the highest priority financial crime risks.

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