Our Financial crime webinar series provided insights into key issues and financial crime risks that are high on the FCA and law enforcement agendas.
These concise 30-minute sessions were tailored to equip you with practical guidance on how to approach and mitigate the risks. They covered the most recent regulatory developments and their application to the regulated sectors, particularly important as the FCA moves into the 2nd half of its 3-year strategy to reduce and prevent financial crime.
Session 1: Tuesday 30 April – ECCTA
Overview: The economic crime reforms introduced under the UK’s Economic Crime and Corporate Transparency Act (ECCTA) contains the most fundamental changes to the law on economic crime since the Bribery Act. The reforms will require organisations in all sectors to take steps to ensure that they meet the requirements under the Act. We discussed how clients have responded to the reforms so far, how the reforms will apply in practice and how clients can mitigate the increased corporate risks the new reforms carry, based on the anticipated statutory guidance (to be published shortly).
This discussion includes practical examples of the types of scenarios that will likely engage the new Failure to Prevent Fraud offence/s including: mis-selling, manipulation of financial forecasts/accounts/sales targets or issuing misleading company statements (e.g. greenwashing) and some common challenges and themes, such as the extra-jurisdictional reach of the reforms, that have emerged from client feedback to date.
Speakers: Camilla de Silva and Jon Malik
Session 2: Tuesday 21 May – Common themes from s165/166 and lessons from Final Notices
Overview: Half of the total FCA fines in the last 2 years have resulted from failings to manage financial crime risk and financial crime remains one of the FCA’s top priorities going into FY 23/24. In this session we shared some of the key risk management lessons that can be gleaned from those Final Notices, together with best practice tips and tricks for dealing with s165 requirements, s166 skilled person appointments and/or voluntary requirements, which are a currently favoured tool for financial crime supervisory oversight.
Speakers: Caroline Hunter-Yeats, Tom Makin, Douglas Robinson and Matt Handfield
Session 3: Tuesday 11 June – APP fraud
Overview: Fraud was the most common crime type between April 2022-March 2023 and authorised push payment (“APP”) fraud caused £485m in losses in 2022. From October 2024 banks and payment service providers will be required to pay mandatory compensation for APP fraud. The final rules for mandatory reimbursement are still being finalised and there is much for the industry to do to get ready for the new regime. In this session we covered the new reimbursement regime and related civil and criminal liability risks arising from APP fraud.
Speakers: Robert Allen, Douglas Robinson, Oliver Irons and Neelam Hundal
Session 4: Tuesday 2 July – Sanctions outlook and enforcement
Overview: Following a busy two years for sanctions compliance, we looked ahead to what may be next under Russia and other sanctions regimes. With the anticipated focus of the FCA and UK law enforcement bodies moving to enforcement of sanctions breaches and related controls failings, we considered what to expect from an intensifying enforcement environment.
Speakers: Cherie Spinks, Adam Brown and Tom Bowen
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