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16) Is financial crime considered at senior management level within your organisation?

August 19, 2021
Financial Risk
Fraud Officer
Compliance Officer

Answer yes if your organisation has a member of senior management who is responsible for financial crime or a process for ensuring financial crime risk & treatment action is considered by the senior management team.

Entities regulated by the FCA have specific statutory and regulatory requirements that they have to implement to reduce the risk of fraud, and to enable it's detection. This covers:

  • credit institutions;
  • financial institutions;
  • auditors, insolvency practitioners, external accountants and tax advisers;
  • independent legal professionals;
  • trust or company service providers;
  • estate agents;
  • high value dealers;
  • casinos.

For non-regulated entities fraud is still a risk, but there is no regulatory need for any anti-fraud controls to be implemented. If your business is still considered at high risk for fraud, you may wish to still implement a framework for detecting, preventing, and investigating fraud.

Compliance with financial rules and regulations is an important responsibility of any business. Both large and small businesses often require assistance with this, and therefore appoint a full time compliance officer.

A compliance officer is responsible for maintaining their company's compliance with regulation and legal requirements. A large part of this is maintaining compliance with fraud requirements.

Typically the compliance officer will be responsible for the organisation's anti-money laundering framework, trade and financial sanctions compliance, and fraud framework.

How to implement the control

If your company is FCA regulated it is best you seek professional external advice on how to comply with anti-fraud requirements. We'd recommend speaking to a lawyer or regulatory consultant.

If your company is not FCA regulated but you are worried about the impact fraud is having on your business, again we recommend that you speak to a financial crime lawyer or regulatory consultant.

If you are not FCA regulated, and fraud is not impacting your business, then you may not need to implement this control.

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