Vulnerable Customers in Wealth Management: A Practical Guide
Identifying vulnerable clients is one of the most technically and ethically demanding obligations the Consumer Duty places on wealth managers. Done well, it protects clients at the moments they most need it. Done as a compliance exercise, it generates documentation that satisfies no one. The …
EDD Triggers: High-Risk Countries, Sectors and Products
Enhanced due diligence is not a catch-all for any customer the firm is uncertain about — it is a defined set of measures triggered by specific risk factors. Knowing precisely when EDD is required, and what it must involve, is fundamental to a compliant and …
Transaction Monitoring Tuning: Balancing Detection and Noise
Transaction monitoring is only as good as its calibration. A system generating hundreds of unactionable alerts daily is not more effective than one generating ten meaningful ones — it may be less effective, because alert fatigue erodes the quality of the human review that makes …
MLR 2017 Firm-Wide Risk Assessment: Structure and Content
The firm-wide risk assessment is the foundation of every AML compliance programme. Without a well-structured, specific and regularly updated risk assessment, a firm’s AML controls — however individually sound — are built on uncertain ground that will not withstand FCA scrutiny. Regulation 18 of the …
Sanctions Screening for Payment Firms: Speed vs Accuracy
For payment firms processing thousands of transactions per day, sanctions screening creates a direct tension between two non-negotiable requirements: screening must be comprehensive enough to catch genuine matches, and it must be fast enough not to disrupt the payment processing that customers depend on. Sanctions …
Tier 1 and Tier 2 Conduct Rules: Who They Apply To
The SMCR Conduct Rules apply to virtually everyone working at an FCA-regulated firm — but they do not apply equally. The distinction between Tier 1 (Individual Conduct Rules) and Tier 2 (Senior Manager Conduct Rules) determines what each person is required to do and, critically, …
Reasonable Steps Under SMCR: What the FCA Looks For
“Reasonable steps” is the central concept of SMCR personal accountability — and the FCA’s track record in enforcement shows exactly what it means in practice. This is not an abstract standard. The FCA assesses it against concrete questions about what the SMF holder knew, what …
Statement of Responsibilities: Drafting Tips for New SMFs
The Statement of Responsibilities is the document that defines what you are personally accountable for as a Senior Manager. Done well, it protects you and the firm. Done poorly, it creates ambiguity that the FCA will exploit if something goes wrong. Every proposed SMF holder …
Annual Certification: Practical Steps for Certified Persons
Annual certification is a genuine compliance obligation — not a bureaucratic formality. Firms that treat it as a tick-box exercise, and individuals who wait passively for their employer to manage it for them, both regularly find themselves in difficulty when the FCA asks questions. Under …
Senior manager handover: best practice when SMFs leave
Senior manager handover: best practice when SMFs leave When a Senior Manager leaves an FCA-regulated firm, the event triggers a series of regulatory and governance obligations that go significantly beyond a standard employment notice period and handover. The departing senior manager must be withdrawn from …
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