Supplier Risk Management is key for effective management and oversight of outsourced functions. Insurance businesses must avoid undue additional risk through outsourcing, whilst achieving efficiency and quality.
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Frequently Asked Questions
A business credit score calculates the probability of a company becoming insolvent within the next 12 months. We highlight creditworthiness through a red/amber/green system of credit scoring, with a result of 1-100. Any changes to scores are reported to users by alerts and dashboards.
REG data is collected from hundreds of sources including sanctions lists, and official registries like Companies House. We are constantly reviewing quality and consistency of data sources to ensure we deliver high quality, up-to-date information.
The Anti-Money Laundering regulations are governed by 4 Acts: The Proceeds of Crime Art, The Serious Organised Crime and Police Act, The Terrorist Act and the Money Laundering Regulations. Failure to report suspicious activity can carry a criminal sentence and lead to substantial fines from the relevant regulatory body.
On 10th January 2020, changes to the UK Government Money Laundering Regulations came into force. They update the UK’s AML regime to incorporate international standards set by the Financial Action Task Force (FATF) and to transpose the EU’s 5th Money Laundering Directive.
Although mortgage brokers, general insurers and general insurance brokers are not subject to FCA’s AML rules and the Money Laundering Regulations, they still need systems and controls to prevent financial crime. They are also subject to the Proceeds of Crime Act 2002. Without these controls (e.g. no process for reporting knowledge or suspicions of money laundering) they will be at risk of committing money-laundering offences.
The risk-based approach means a focus on outputs. Firms that apply a risk-based approach to anti-money laundering (AML) will focus AML resources where they will have the biggest impact.
Firms must have in place policies and procedures in relation to customer due diligence and monitoring, among others, but neither the law FCA rules prescribe in detail how firms have to do this. Firms’ practices will vary depending on the nature of the money-laundering risks they face and the type of transactions processed.
Firms applying a risk-based approach need to be proactive in seeking out information about money-laundering trends and threats from external sources, such as law enforcement, as well as relying on their own experiences and observations. This allows firms to effectively review and revise their use of AML tools to fit the specific risks that they face.
Standard AML checks do not screen clients against Her Majesty’s Treasury (HMT) list, while PEPs are not necessarily included in financial sanction checks. FCA registered companies are required to run the checks as day-to-day due diligence, not only to reduce their own company’s risk exposure, but to also comply with the current guidelines and stay within the law. With a 30-40% increase every year in the PEPs list alone, it is important to screen new and existing clients to make sure they are compliant with the AML guidelines.
This check will allow you to see if a company has been sanctioned or if a politically exposed person has a connection to the company. There is no unique definition of a PEP, in fact the criteria varies from country to country and even company to company. A PEP does not necessarily mean someone who is involved in politics, it could include immediate family members, close business associates or even senior executives. These are key individuals and are important to check as a PEP presents a higher risk for potential bribery and corruption due to their position in society and the influence they may hold.
If a company has been sanctioned they have been issued a penalty by law for failure to comply with a court order, law or regulation. It is illegal to deal with a sanctioned company, so it is important to run a check on them and be compliant with the current guidelines set in place. If your company deals with a sanctioned company, even if you are a limited company, you may be personally prosecuted for this and could risk going to jail.
Your customers’ circumstances can change frequently, meaning that a historic check may not reflect a customer’s status now. For this reason ongoing monitoring is a critical component of your compliance with the 5th Anti-Money Laundering Directive.
There is no definitive guideline to say how often your PEPs and Sanctions should be updated. However, our ongoing monitoring service will check the status of the customers you monitor on a daily basis to keep your records up to date.