2017年-FCA英国金融行为监管局_financial_crime_data_return_3页_183kb

Regulator Assessment Summary: Financial Crime Data Return (REP-CRIM)

Core Content

The Financial Crime Data Return (REP-CRIM) is a new regulatory requirement introduced by the Financial Conduct Authority (FCA) to enhance financial crime supervision in the UK. The proposal aims to shift from ad hoc data requests to a more systematic and risk-sensitive approach by collecting routine data from regulated firms on their financial crime systems and controls. This initiative is part of the FCA's broader efforts to align with global standards and improve the oversight of financial crime risks.

The commencement date for REP-CRIM is 31 December 2016, and it applies to firms in the life insurance sector across all areas of the UK. The proposal is domestic in origin and does not include implementation of a Cutting Red Tape review.

Affected Business Types

The following types of firms are subject to REP-CRIM under the Money Laundering Regulations (MLRs):

• Banks
• Building societies
• Designated investment firms
• Investment firms
• Mortgage lenders
• Electronic money institutions
• Full permission consumer credit firms
• Life insurers
• Retail investment intermediaries
• Mortgage intermediaries

However, a proportionality rule applies to some of these firms, exempting those with revenue of less than £5 million (as of the last accounting reference date) from the requirement. This includes:

• Retail investment intermediaries
• Mortgage intermediaries
• Investment firms
• Consumer credit firms
• Electronic money institutions

As a result, the majority of small firms are not affected by REP-CRIM.

Cost and Benefit Analysis

Costs

The FCA estimated the costs associated with completing REP-CRIM based on responses from trade bodies and firms. The costs vary significantly depending on the firm's size and complexity:

• Complex firms (with multiple subsidiaries):

  • One-off cost per firm: £77,000 on average
  • Ongoing annual cost: Negligible
  • Number of firms: 13
  • Total one-off cost: £1 million
  • Total ongoing cost: Negligible

• Non-complex firms:

  • One-off cost per firm: £7,000 on average
  • Ongoing annual cost: £500 on average
  • Number of firms: 1,400
  • Total one-off cost: £9.9 million
  • Total ongoing cost: £0.7 million

• Total estimated cost: £10.9 million (one-off) + £0.7 million (ongoing) = £11.6 million over five years.

Benefits

The benefits of REP-CRIM are non-financial and focus on enhancing the FCA's ability to supervise financial crime more effectively. The key benefits include:

• Improved risk assessment and targeted supervision based on consistent and high-quality data.
• A more hostile environment for money launderers and financial criminals.
• Reduction in the need for ad hoc data requests and on-site visits, which improves efficiency and resource allocation.

Due to the intangible nature of these benefits, they cannot be quantified in financial terms. The FCA emphasizes that the proposal contributes to reducing crime and social harm without a direct financial cost to the public.

Additional Information for BIT Score Validation

• Price base year: 2016
• Implementation date: 31 December 2016
• Duration of policy: 10 years
• Business Net Present Value: -£16.9 million
• Net cost to business (EANDCB): £10.9 million (one-off) + £0.7 million (ongoing) = £11.6 million
• BIT score: 9.0

The BIT score of 9.0 indicates that the net cost to business for five years is £10.9 million, with ongoing costs of £0.7 million. This score reflects the overall financial impact of the proposal on the business sector.