Financial sanctions systems and controls for financial services firms


Published by a ½Û×ÓÊÓƵ Financial Services expert
Practice notes

Financial sanctions systems and controls for financial services firms


Published by a ½Û×ÓÊÓƵ Financial Services expert

Practice notes

UK financial Sanctions obligations apply to all individuals and legal entities who are within or undertake activities within the UK; this Practice Note focuses on the implications for firms regulated by the Financial Conduct Authority (FCA) under the Financial Services and Markets Act 2000 (FSMA 2000) and for e-money and payment institutions and cryptoasset businesses within the FCA’s supervisory scope.

The FCA is not responsible for enforcing financial sanctions, its role is to ensure that the firms it supervises have adequate systems and controls to comply with the UK’s financial sanctions regime. This Practice Note addresses the FCA's requirements and expectations for a firm's financial sanctions systems and controls in relation to:

  1. •

    risk assessments

  2. •

    policies and procedures

  3. •

    governance and senior management responsibility

  4. •

    management information (MI)

  5. •

    resource provision

  6. •

    communication, training and staff awareness

  7. •

    international sanctions Compliance

The FCA also expects firms’ sanctions systems and controls to address:

  1. •

    reporting obligations to the FCA, Office of Financial Sanctions Implementation (OFSI), the Office of Trade Sanctions Implementation

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Jurisdiction(s):
United Kingdom
Related legal acts:
Key definition:
Sanction definition
What does Sanction mean?

An adverse consequence to a party of failing to comply with a rule, practice direction or court order.

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