Financial Crime Prevention Working Group

Help firms understand, implement and develop industry good practice guides

Industry challenge

The Home Office has reported that serious and organised crime is estimated to cost the UK at least £37 billion each year, with suspicious activity reports rising 10% year on year. Firms that fail to prevent money laundering, or have inadequate systems and controls, tend to pay a heavy price in the form of declining revenues, customer dissatisfaction, huge financial penalties, loss of reputation, and fall in stock prices.

Group purpose

The TISA Financial Crime Working Group meets quarterly and addresses the challenges faced by firms in administering measures to counter money laundering, terrorist financing, financial and trade sanctions, bribery, corruption, fraud, market abuse, tax evasion and other relevant anti-financial crime legislation.

There are significant new requirements imposed on firms, especially following proposed changes to Companies House reporting and in respect of Trusts Registration where millions of trusts have come into scope – for many wealth management firms it is not unusual to have tens of thousands of trusts as customers, which need verification – and for which procedures need to be in place. Once the Reform has received Royal Assent the group will update the TISA Guide. A Companies House representative attended the December Working Group meeting and presented on the reform.

Area of Focus

  • Formulate, and pursue, TISA initiatives related to financial crime designed to facilitate beneficial change or to share best practice
  • Provide a meeting point where best operating and technical practice can be shared, and common challenges debated
  • The group has been engaged and active in drafting additional sections to be included in TISA’s Financial Crime Prevention Best Practice Guides including Sanctions (especially in relation to Russian investment sanctions) Trusts Registration (where there is overlap with work in the Taxation Committee) and Companies House Verification (which also has some links with Sanctions)
  • There are significant new requirements imposed on firms, especially following proposed changes to Companies House reporting and in respect of Trusts Registration where millions of trusts have come into scope – for many wealth management firms it is not unusual to have tens of thousands of trusts as customers, which need verification – and for which procedures need to be in place. Once the Reform has received Royal Assent the group will update the TISA Guide. A Companies House representative will be attending the next Working Group meeting to present on the reform – delayed from December due to delay in Royal Assent.
  • Guides all now finalised
  • Review of KYC and PEPs underway following the recent UK “debanking” controversy – There is a wider issue with firms having difficulties opening accounts and trustees experiencing difficulties. A meeting is being arranged with UK Finance to review whether updated guidance is needed. The TISA lead (as Chair of the Chelmsford Diocesan Board of Finance ) has been asked to draft a question to put in the House of Lords.
  • Some member firms with a regulatory presence in Luxembourg are receiving complex due diligence requests from Fund Managers, relating to areas such as signatories on nominee accounts as they see platforms as sub-distributors. The authorities are aware of the issues the requests are causing and have provided webinars to assist firms in their understanding of what they require, but members are sharing their challenges and discussing possible solutions.
  • Pension administration – Financial Crime sub-group meeting held at the end of November to share financial crime related issues and seek agreement on priority to take forward, based on level of interest.
  • Financial Crime Conference held in January with HMT speaker

Group strategy

The purpose of the TISA Financial Crime Prevention Working Group (FCPWG) is to address the challenges faced by firms in administering measures to counter money laundering, terrorist financing, financial and trade sanctions, bribery, corruption, fraud, tax evasion and other relevant anti-financial crime legislation. It is designed to serve the needs of those individuals and organisations interested in the issues surrounding matters where best operating and technical practice can be shared, and common challenges debated.

It acts as a focal point for TISA about the operational aspects of issues relating to financial crime measures, including technical and regulatory matters, which specifically impact on firm’s administration and procedures. 

The group may also formulate, and pursue, strategic initiatives related to financial crime prevention designed to bring about or facilitate beneficial change. TISA works closely with the FCA, City of London Police, Corporation of London, JMLSG and the UK Government.

Participating member firms

A J Bell Securities Limited
abrdn
Acuant
Aegon UK PLC
Ashurst Risk Advisory LLP
Allfunds Bank S.A.U
Aviva Plc
Bank of Ireland
Baringa Partners LLP
Brooks Macdonald
Carmignac Gestion Luxembourg S.A. (UK Branch)
Digital Moneybox
Ernst & Young
Fidelity International
Fluro
FNZ
Folk2Folk
Freetrade Limited
Hargreaves Lansdown
Invesco
James Sharp
JTC Group
Legal & General

LexisNexis Risk Solutions
LV=
M&G Investments
Margetts Fund Management Ltd
Nationwide
Ninety One UK
Northern Trust
One Savings Bank
OneFamily
Optima Consulting Partners Limited
Orbis Investments (U.K.) Limited
Parmenion Capital Partners LLP
Platform One Limited
Quilter (formerly Old Mutual Wealth)
Quilter Cheviot Limited
Quilter PLC
Rathbone Bros Plc
RBC Brewin Dolphin
Santander UK Plc
SIX Financial Information
SS&C
SS&C Financial Services Europe Limited
Thesis Asset Management

Lisa Laybourn, Head of Technical Policy and Risk,
leads on this work at TISA

Chair: Katarina Cook, Brewin Dolphin

Deputy Chair: Brian Swainston, Fidelity

If you are a TISA member who would like to get involved with this work, please get in touch

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