10 Jan 2019
A key element in the application of the risk-based approach (RBA) to financial crime is the identification by a firm of those countries with which its customers are closely linked and which are also adjudged to be high risk in financial crime terms.
There are many lists of such high-risk countries produced by both public authorities and private organisations that may assist a firm in the production of its own high-risk list.
The purpose of this article is to consider a few issues around some lists produced by the public sector.
FCA survey of annual financial crime returns
The FCA has required some 2,000 of the largest UK firms to submit an annual Financial Crime Return (FCR).
The purpose of the FCR is to increase the FCA’s understanding of a variety of issues on a firm by firm basis, such as the total number of clients, the number of high risk clients, the number of internal suspicious reports and external suspicious activity reports (SARS) submitted as well as the most common types of fraud.
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