Bribery & Corruption in Financial Services

If you believe you have identified a potential risk or have concerns about actions that are suspicious you should raise these. Normally you should suspend the transaction if you suspect money laundering or terrorist financing. If this is not practical - or not safe – you should make the report as soon as possible after the transaction is completed.

Your firm should have internal policies in place to guide you and in most cases the first discussion should be internally with your line manage or other designated person.

However, if you feel that these avenues are not appropriate then you can raise your concern directly with the FCA https://www.fca.org.uk/firms/whistleblowing

 You may find the following information useful in considering your next steps:

 

What is considered to be Bribery & Corruption in Financial Services?

Any kind of criminal conduct relating to money or to financial services or markets, including any offence involving:

  • fraud or dishonesty
  • misconduct in, or misuse of information relating to, a financial market
  • handling the proceeds of crime
  • the financing of terrorism.

Firms must have robust governance, effective risk procedures and adequate internal control mechanisms to manage their financial crime risk to: detect, prevent and deter financial crime.

The approaches involve assessing the risks that a business may be used for the purposes of financial crime and then mitigating those risks effectively through:

  • identifying their customers
  • understanding the relationship with them
  • monitoring the way they use services to identity anything suspicious.

Senior management are responsible for managing financial crime risks and be actively engaged in addressing these risks.

 

What can you do if you identify a risk?

You will have an internal policy that outlines how to raise concerns. It is always best to try to resolve this informally in the first instance with your line manager.

A report of any suspicious transaction or activity should be made to the designated person. They will decide whether to send a report or ‘disclosure’ about the incident to the National Crime Authority. They do this by making a Suspicious Activity Report.

Normally you should suspend the transaction if you suspect money laundering or terrorist financing. If it’s not practical - or not safe - to suspend the transaction, make the report as soon as possible after the transaction is completed.

If you feel that these avenues are not appropriate, then you can raise your concern directly with the FCA https://www.fca.org.uk/firms/whistleblowing

 

Source and further information can be found from

The source material used to compile the above overview and further information on this topic can be found at:

Financial Conduct Authority https://www.fca.org.uk/firms/financial-crime

Article https://www.fca.org.uk/news/speeches/more-effective-approach-combatting-financial-crime



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