The UK’s financial services regulator has today published a report based on its review of sanctions compliance by a sample of 90 regulated firms.
The FCA emphasised the importance it places on compliance with sanctions and the proactive approach it intends to take to enforcement.
The FCA also published examples of what it considers to be good practice and bad practice. The examples of bad practice include:
(i) insufficient information given to management on sanctions risks, and insufficient management attention;
(ii) global sanctions policies that are insufficiently attuned to the specifics of the UK’s regime;
(iii) over-reliance on third-party screening tools without sufficient oversight or attention to the detail and calibration of such tools;
(iv) insufficient contingency planning in advance of anticipated changes to sanctions;
(v) insufficient resources applied to sanctions compliance resulting in significant backlogs; and
(vi) insufficient and inappropriate calibration of of screening tools allowing either too many false positives, or gaps in screening hits.