FCA Business Plan for 2015/16 Includes Focus on Financial Crime

24 March 2015

On 24 March 2015, the FCA released its business plan for 2015/16. The plan focuses on its main roles of authorisation, supervision, and enforcement and highlights its continuing focus on ensuring businesses anti-money laundering controls are sufficient.

For 2015/16 the FCA’s financial crime foci will be money laundering (“AML”) and bribery and corruption (although the latter gets no further mention).

In respect of AML it will implement an “enhanced anti-money laundering supervision strategy”. This will include the “deep-dive” assessments conducted on four major banks’ AML policies each year and continue the reviews, which were conducted for the first time last year, on smaller firms which the FCA consider at a high risk of money laundering. 

Notably, all of the features of its enhanced anti-money laundering supervision strategy will already be familiar to practitioners and it is not clear from the business plan what enhancements this programme will have on last year’s review.

Interestingly, last year’s report noted that the FCA’s supervisory role in respect of AML extended beyond ensuring that firms follow their AML processes, and included review of the quality of judgements those firms made about money laundering risks and their general money laundering culture. While not mentioned in this year’s report, we presume the FCA will be taking the same approach this year.

Finally, the FCA highlights that the implementation of the fourth Anti-Money Laundering Directive, and providing better arrangements and protections for whistleblowers will also be priorities this year.

The full report can be found here.