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AFB Practice Roundtable: UK Sanctions Controls – The FCA’s Thematic Review and Supervisory Initiatives

AFB is holding an in-person roundtable hosted by DWF Law LLP, to provide members with an opportunity to engage in a discussion on the areas covered in the FCA’s thematic review on sanctions compliance.

Nine months on from the FCA’s first publication of its work on the Sanctions regime, the FCA has launched the Sanctions Modular Assessment Proactive Programme (“SMAPP”), which is being rolled out across financial services. This roundtable follows the recent AFB roundtable hosted by DWF in March and will look specifically at how firms can prepare for the SMAPP.

It is becoming increasingly more challenging for firms to ensure that Systems & Controls remain fit for purpose in the identification, treatment and reporting of Designated Persons.  The roundtable will provide practical insight and takeaways drawn from the experiences of member firms and DWF into how to remain compliant.

Attendees will be invited to share their perspectives and knowledge on how they are meeting the challenges of compliance. Attendees will also be able to put questions to the DWF experts on regulatory expectations, Sanctions rules, Systems and Controls and Financial Crime prevention.

AFB will circulate an agenda and a series of questions in advance to those registered to attend, which will be used to add to the discussion.

The Chatham House rule will apply to this roundtable to encourage open dialogue and discussion.

There will be refreshments and networking from 15:30 before the roundtable starts at 16:00, Followed by drinks, nibbles and further networking at DWF’s offices.

Capacity for the roundtable is limited to 25 and one person per member Bank.

Why attend?

International Banks face challenges in ensuring compliance with UK Regulations. The Roundtable will allow members to share knowledge on Sanctions practices with expert input and practical tips provided. The session will cover; Risk Appetite, the SMAPP and the FCA’s Thematic review on the following key areas: Governance and oversight, Screening, Skills and Resources, Customer Due Diligence, Breach Reporting and FCA Notifications. The session will also cover some key common issues faced by banks.

Who should attend?

  • Heads of Compliance/ Compliance Officers
  • Senior Management Function holders
  • Money Laundering Reporting Officers

Facilitators

Andrew Jacobs – Partner and Head of Regulatory Consulting 

Andrew leads DWF’s regulatory compliance offering for our clients globally. Andrew has been a regulatory professional for 20 years, working across a number of different areas of the financial services sector, based within the UK and internationally. He has also provided advice to clients in a range of international jurisdictions based upon UK and Home State regulation.

Andrew has been a partner at two top ten accounting firms and helped develop their consulting practices providing regulatory expertise to clients. He has also held board-level positions at a number of different wealth, advisory and distribution firms, where he has been FCA approved having responsibility for; Compliance oversight, Risk and Anti-Money Laundering (AML). He has the experience of advising a range of businesses and in particular, Overseas Banks, for whom he has undertaken a significant number of Skilled Person’s reviews in the past. These have been across a range of the FCA’s Skilled Person Lots, and he has acted as a Skilled Person in respect of Lots C, D & E. Andrew has also supported a firm subject to the SMAPP.

Andrew holds the CII Diploma in Financial Advice (Dip PFS), the CII Certificate in Discretionary Investment Management (Cert PFS (DM)) and is a Chartered Member of the Chartered Securities for Securities and Investments (Chartered MCSI). He has led on thought leadership pieces on the subjects of the Cost of Financial Crime to businesses and worked alongside a number of Associations, including the APCC, AFB, CISI and FLA. 

Craig Broom – Associate Director – Financial Crime Compliance Lead

Craig is the Financial Crime Compliance Lead in DWF’s Regulatory Consulting practice with over a decade of practical experience working within the Financial Services industry. Craig has held multiple Senior Management roles in Financial Crime Compliance and Regulatory Compliance (CF10/11 and SMF 16/17) in Wealth Management and for a Foreign Bank.

In his capacity as an MLRO he has undertaken the lead role in navigating multiple financial crime Skilled Person reviews as well as being the key point of contact with the FCAs Financial Crime Supervisory Team. Craig has both technical and practical experience with Sanctions Frameworks, where for example, he has carried out framework enhancements, a remediation exercise on Customer / Enhanced Due Diligence, Risk Assessments and Sanction screening.

Craig has also advised and provided technical guidance for firms with their screening calibration, testing of screening systems, OFSI and FCA reporting obligations and dealing with a Designated Person or when a client has holdings in a Designated Person. More generally, dealing with the complex nature of the sanctions regime and associated Risk Assessments. Craig has also supported a firm subject to the SMAPP. Craig was a former member of the AFB Compliance Advisory Committee.

Logistics

Cost:                Included in the AFB membership (no fee)

Location:          DWF, 20 Fenchurch Street London EC3M 3AG (please bring ID to pass building security)

Date:                Thursday, 4 July 2024

Time:                16:00 – 17:30 (Arrival & Refreshments from 15:30)

                          Drinks and nibbles from 17:30 – 19:00

If you would like to submit a question before or have any specific questions or areas that you would like the roundtable to address, please send them to the AFB at secretariat@foreignbanks.org.uk. You will receive details on how to join the roundtable a week before the event.