The FCA seeks to adopt a ‘risk-based’ approach to supervision. This means that its aim is to concentrate supervisory resources where the risk is greatest. It also expects the financial industry to follow the same principle when designing anti-money laundering and anti-bribery controls.
The FCA has identified which registered businesses are most likely to be used as a means of laundering the proceeds of criminal activity and which business models are most vulnerable to bribery and corruption.
Vulnerability in both areas may increase in certain territories, but this does not mean that there is no risk when a firm is operating only in the UK.
Supervisory tools used are:
- Questionnaires:requests for information from management about the business and its anti-money laundering or anti-bribery procedures.
- Ad hoc information requests: examples may include documents such as organisational charts, documents setting out internal procedures, breaches logs and job descriptions of senior management.
- Mystery shopping:commissioning ‘mystery shoppers’ to pose as members of the public seeking to become customers.
- Helpline: a helpline that will be able to answer registeredbusinesses’ queries by telephone (also via email or letter).
- Thematic work:involving a number of registered businesses in a piece of work on a particular topic.
- Visits: regulators’ staff may visit a business to meet senior management and examine documents.