2017年-FCA英国金融行为监管局_consumer_credit_protecting_your_business_from_financial_crime_5页_158kb

Regulator Assessment Summary: Consumer Credit - Protecting Your Business from Financial Crime

Core Content

This document outlines the FCA's assessment of a proposed regulatory activity titled "Consumer Credit: Protecting your business from financial crime". The assessment was conducted in March 2016, with the implementation date set for November 2016. The proposal is domestic in origin and does not include the implementation of a Cutting Red Tape review. It affects the whole of the UK, targeting authorised consumer credit firms subject to the Money Laundering Regulations 2007 and the Proceeds of Crime Act.

The main initiative is the publication of a financial crime booklet as part of a knowledge sharing/awareness raising effort. This booklet is not a new regulatory requirement but a reminder of existing obligations, designed to help firms re-familiarise themselves with their responsibilities under the FCA Handbook and related legislation.

Main Points

• Purpose: To raise awareness and ensure that consumer credit firms are aware of their obligations in preventing financial crime.
• Nature of the Initiative: A self-assessment booklet based on existing rules and guidance.
• Target Audience: All authorised consumer credit firms in the UK.
• Estimated Number of Firms: 3,500 firms, based on FCA data.
• Costs: The familiarisation cost is estimated at £168,000 over 10 years, with no implementation or ongoing costs.
• BIT Score: 0, as the cost is spread over 10 years and multiplied by 5, resulting in a score of 0.
• Impact: The booklet serves as a compliance reminder, reinforcing existing rules without introducing new obligations.

Key Regulatory Provisions

The booklet links self-assessment questions to the following existing rules and guidance:

These areas are aligned with the FCA Handbook and financial crime principles, including:

• SYSC 3.2.6R and SYSC 6.1.1R (systems and controls for financial crime prevention)
• PRIN 2.1.1R (Principles for Businesses)
• APER 2.1.2P (Statements of Principle for Approved Persons)
• SYSC 3.2.6AR to SYSC 3.2.6JG and SYSC 6.3 (guidance on money laundering and customer due diligence)

Cost and Benefit Breakdown

Costs

• Familiarisation Cost: Estimated at £168,000 for 3,500 firms.
  • Based on a reading time of 1 hour per firm at a reading rate of 100 words per minute.
  • Hourly rate: £48/hour (based on average compliance staff salary).
• Implementation Cost: £0 (as the booklet is based on existing rules).
• Ongoing Cost: £0 (no new obligations or procedures introduced).

Benefits

• Awareness Raising: Helps firms understand and comply with existing financial crime rules.
• Risk Management: Encourages firms to maintain effective systems and controls to detect and prevent financial crime.
• Alignment with FCA Priorities: Supports the government’s goal of making the UK financial services sector a hostile environment for criminals.
• Compliance Support: Provides self-assessment questions and examples of good and poor practice to aid internal compliance processes.

Additional Information

The booklet is intended to be a complement to the Financial Crime: a guide for firms, which contains detailed guidance on the FCA Handbook rules and principles. It is not part of the FCA Handbook itself but draws from it.

For further reference, the following documents are provided:

• Consumer Credit: Protecting Your Business from Financial Crime
• Financial Crime: a guide for firms

Conclusion

The proposed booklet is a non-binding awareness initiative that aims to reinforce existing compliance obligations. It does not introduce new regulatory requirements, but rather serves as a guidance tool to help firms review and update their procedures. The estimated cost is relatively low, and the benefits are primarily in terms of compliance awareness and risk mitigation.