Financial Conduct Authority of the United Kingdom. The FCA regulates financial firms providing services to consumers and maintains the integrity of the UK’s financial markets. The FCA has the following role in the sanctions context: The FCA is responsible for ensuring that firms have adequate systems and controls to comply with U.K. sanctions requirements. In 2010, the FCA (at that time called the FSA) fined members of the Royal Bank of Scotland Group (RBSG) £5.6m for failing to have adequate systems and controls in place to prevent breaches of UK financial sanctions. Although there is no specific obligation in the FCA Handbook requiring firms to notify the FCA of a financial sanctions breach, Principle 11 of FCA Principles for Business requires firms to keep the FCA advised of any relevant issues of which the FCA would normally expect notice. See: http://www.fca.org.uk/about/what/enforcing/sanctions. The FCA issued a report in 2014 about “How small banks manage money laundering and sanctions risk: FCA, November 2014.” “Poor management of alerts from sanctions screening and transaction monitoring” were among the issues identified through the FCA supervisory framework.

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