The review focused on wholesale brokers and was informed by engagement with a range of market actors.
Key findings from the review include:
- Underestimation of the ML risks brokers are exposed to;
- Overreliance on due diligence checks being conducted by other participants in the transaction chain;
- Limited information sharing between market participants; and
- Insufficient knowledge of the Money Laundering Through the Markets (MLTM) Suspicious Activity Reports (SAR) glossary code as highlighted by other reviews.
✅ Brokers regulated by the FCA should review their due diligence frameworks are comprehensive and robust in line with the expectations of the regulator.
Advisory and Transformation
AML/CTF/CPF
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