The SRA has this week issued an update to its warning notice on suspicious activity reports which was originally published in 2014.
The update comes at a time of increased regulatory scrutiny and reflects the changing AML/CTF landscape (e.g. increasing regulatory requirements, evolving criminal threats and a more active supervisory regime). The SRA now expects firms not only to have controls in place, but to ensure those controls are effective, reviewed regularly, and supported by training and documented procedures.
The warning notice has been revised to reflect current AML/CTF legislation and LSAG guidance as well as a more forceful supervisory stance given increased enforcement activity. There is now a greater emphasis on ongoing monitoring, not just initial CDD and higher expectations of completeness and usefulness in SARs (even when information is limited) as well as more explicit direction at senior compliance figures (COLP/COFA/MLRO/MLCO).
To read the warning notice, click here.
