Overview

The FSA’s approach has serious implications and lessons for all in the UK who conduct business within the UK and beyond, whether that business is regulated activity for the purposes of FSMA or not.

The penalty was in respect of a breach of Principle 3 of the FSA’s Principles for Businesses, which provides that: “A firm must take reasonable care to organise and control its affairs responsibly and effectively, with adequate risk management systems”. The Notice concerned systemic failings in the customer due diligence steps for, and the process for making payments to,
overseas third parties, particularly where the third party was based in a jurisdiction in which corrupt practices are thought to be widespread.

To read more, click 'View Briefing'