Blogs

 In March 2019, the FCA published “The Directory”. Following on from the Senior Manager’s regime, there is a reduced number of people within a firm that are required to be approved by the FCA and PRA, and therefore a reduced number of individuals names will appear on the Financial Services register.

Consequently, those carrying out customer function type roles such as those who provide financial advice, help with pension transfers, traders, portfolio managers and additional directors will no longer be approved by the FCA and PRA and will not appear on the register. 

In February 2019, we saw the UK’s Office of Financial Sanctions Implementation (OFSI) (not to be confused with the Canadian regulator the Office of the Superintendent of Financial Institutions (OSFI) impose a £5000 fine against London based Raphaels Bank, the first fine levied by the agency since its creation in 2016. 

In February 2019, the FATF issued a list of those jurisdictions that have strategic AML/CFT deficiencies and therefore present a risk to the financial system until commitments to address the deficiencies materialise.  

The listed countries are: 

January 2019 saw the UK’s Transparency International (TI), Corruption Perception Index (CPI) score fall from 8th place to 11th   this being the UK’s lowest score since it hosted the global Anti-Corruption Summit in 2016. This fall in ratings does need to be balanced however against the fact that globally 65 countries ratings fell and one of the biggest falls was the USA who fell from 16th in 2017 to its current 22nd place.    

 In this assessment, adopted at the October 2018 Plenary meeting in Paris and published in December 2018, the UK was classified as having an effective regime in many respects.

However, we were also reminded that the UK is the largest financial services provider in the world and therefore we hold a significant risk that some of the funds that we handle may have links to criminal activity and/or terrorism.