The report includes a review of financial crime controls across a sample of corporate finance firms, identifying both good and poor practices in how firms manage money laundering (ML), bribery and corruption risks.
Key findings include:
➡️ Some firms lacked a clear financial crime risk assessment tailored to their business model, with inadequate consideration of bribery and corruption risks;
➡️ Customer Due Diligence (CDD) was often inconsistent, with some firms failing to verify source of wealth or funds, especially for high-risk clients;
➡️ Enhanced Due Diligence (EDD) procedures were not always applied appropriately, particularly for Politically Exposed Persons (PEPs) and complex transactions;
➡️ Suspicious Activity Reporting (SAR) procedures were not well understood by staff in some firms, and training was often generic or infrequent; and
➡️ Governance and oversight varied, with some firms lacking clear accountability for financial crime compliance or failing to escalate risks appropriately.
✅ Firms should strengthen their financial crime frameworks by conducting robust risk assessments, applying proportionate CDD and EDD, and ensuring staff are adequately trained and supported to identify and escalate concerns.
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