As part of the Commission’s transformation programme a centralised Financial Crime Supervision & Policy Division has been established.
The Benefits of Centralisation
A number of benefits from the centralisation of processes within the Financial Crime Supervision & Policy Division have been realised:
application of a Commission wide risk-based approach to anti-money laundering and countering the financing of terrorism ("AML/CFT");
co-ordinated Regulatory Division on-site visits occurring concurrently to minimise the level of inconvenience to Financial Services Businesses (“FSB”), Non-Regulated Financial Services Businesses (“NRFSBs”) and Prescribed Businesses (“PBs”);
an efficient, effective and consistent approach across all areas of anti-money laundering, countering financial crime and terrorism financing by applying standardised processes;
an established centre of financial crime expertise;
it has enabled Commission-wide service standards to be set;
increased efficiency and optimisation of the Commission’s time during on-site visits.
The Visit Process
FSBs, NRFSBs and PBs receiving visits from the Commission should not see a significant change in the methodology by which the on-site visits were conducted. One difference in the process is the introduction of the AML/CFT Questionnaire. The AML/CFT Questionnaire is a formulation of a series of questions, which is sent to FSBs, NRFSBs and PBs prior to a visit for completion and return together with any supporting documentary evidence.
This provides the FSBs, NRFSBs and PBs who are to be visited with a period of four weeks in which to complete and return the AML/CFT Questionnaire together with supporting documentary evidence to demonstrate compliance with the Regulations, Handbook and Instructions.
Timely completion of the AML/CFT Questionnaire and providing the supporting documentary evidence prior to the visit will provide the Financial Crime Supervision & Policy Division with a greater understanding of the business prior to commencing the on-site visit.
The on-site visit will commence within four weeks of receipt of the AML/CFT Questionnaire and supporting documentary evidence.
To assist the Financial Crime Supervision & Policy Division in being able to provide a complete response to enquiries, it has established an e-mail address to which all AML/CFT questions should be sent for the Division’s consideration: [email protected]
Primary Regulatory Contact
The Regulatory Divisions (Investment Supervision and Policy Division / Banking and Insurance Supervision and Policy Division / Fiduciary Supervision, Policy and Innovations Division) remain the primary point of contact in respect of all other regulatory matters.