January 26, 2022

Volume XII, Number 26

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January 25, 2022

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January 24, 2022

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FCA Publishes Consultation Paper on Extending Annual Financial Crime Reporting Obligation

On August 24, the UK’s Financial Conduct Authority (FCA) published a consultation paper on extending its annual financial crime reporting obligation (REP-CRIM) to a wider range of FCA-regulated firms in the UK (the Consultation Paper).

REP-CRIM aims to identify indicators where there is a potential money laundering risk posed by a regulated firm, based on its regulated activities and customers.

The key changes proposed by the FCA in the Consultation Paper include:

  1. extending the scope of firms obliged to report REP-CRIM information to include any firms involved in regulated activities that potentially pose higher money laundering risk, including certain payment institutions; and

  2. removing “home finance mediation” and “making arrangements with a view to transactions in investments” from the REP-CRIM reportable activities, which are considered by the FCA to be outside of the scope of the money laundering regulations.

The FCA states in the Consultation paper that it did not extend the REP-CRIM obligations to activities considered lower money laundering risks. However, it notes in the Consultation Paper that it may consider doing so in the future.

The FCA plans to issue the final rules and publish a policy statement in the first quarter of 2021.

The Consultation Paper is available here.

©2022 Katten Muchin Rosenman LLPNational Law Review, Volume X, Number 244
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About this Author

Carolyn H. Jackson, International Attorney, Katten Muchin law firm
Partner

Carolyn Jackson is a partner in Katten Muchin Rosenman UK LLP and is a Registered Foreign Lawyer. She provides US financial regulatory legal advice to a broad range of market participants, including commercial banks, investment banks, investment managers, broker-dealers, electronic trading platforms, clearinghouses, trade associations and over-the-counter derivatives service providers.

Carolyn guides clients in the structuring and offering of complex securities, commodities and derivatives transactions and in complying with US securities and commodities laws...

+44 0 20 7776 7625
Nathaniel Lalone, Katten Muchin Law Firm, Financial Institutions Attorney
Senior Associate

Nathaniel Lalone, a partner at Katten Muchin Rosenman UK LLP, has a broad range of experience in the regulation of financial products and financial markets, and frequently provides regulatory and compliance advice to trading venues, clearing houses and buy-side firms active in the over-the-counter (OTC) derivatives, futures and securities markets. He is actively involved in advising clients on the implementation of MiFID 2 and MiFIR in the European Union as well as the international reach of US financial services regulation. He also has significant experience with structuring...

+44 0 20 7776 7629
Neil Robson, private equity fund managers counselor, Katten Law Firm, London
Partner

Neil Robson, a regulatory and compliance partner with Katten Muchin Rosenman LLP, focuses his practice on counseling hedge and private equity fund managers and other investment advisers on operational, regulatory and compliance issues. He regularly addresses Financial Conduct Authority (FCA) and EU authorization and compliance under both the EU Alternative Investment Fund Managers Directive (AIFM Directive) and MiFID, cross-border issues in the financial services sector, market abuse, anti-money laundering and regulatory capital requirements, formations and buyouts of...

44-0-20-7776-7666
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