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Extension of Annual Financial Crime Reporting Obligation (FCA PS21/4)

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The FCA’s annual financial crime reporting obligation (REP-CRIM) is designed to inform the regulator about the overall status of your financial crime related activities. The report provides information about your operating model and jurisdictions, types and locations of customers, information about your high-risk relationships, information about your screening and SAR, your financial crime function in terms of dedicated employees, as well as most prevailing fraudulent activities.

REP-CRIM is a relatively new report for some firms. Whilst it existed historically, it was only applicable to certain firms meeting the specific revenue thresholds. However, effective from 30 Mar 2022, the number of firms that are required to complete this report increased from 2,500 to 7,000 approximately.  More information can be found under the FCA’s Policy Statement PS21/4 – Mar 2021.

The FCA has stated, “As we proposed, we have removed the annual revenue threshold (below which submission was not necessary previously) for some firms carrying on activities that we consider pose higher money laundering risks (for example, firms undertaking the activity of ‘dealing in investments as an agent’ or ‘dealing in investments as principal’). All cryptoasset businesses will need to submit the return, regardless of their size. This will ensure that firms maintain high compliance standards and improve transparency and enable better supervision of such firms by the FCA.”

For the relevant firms, the reports are now available in their Reg Data schedule – “Firms who are now captured under this requirement will be notified through the Reg Data and will require to submit the report within 60 business days of your account referencing data. “

As confirmed in the PS21/4, the firms listed under 1.6 will be required to submit the REP-CRIM irrespective of the annual revenue; this includes all electronic money institutions and payment institutions with some exceptions.

The form itself can be accessed here : REP-CRIM – Financial Crime Report, but relevant firms submit it directly through the Reg Data portal.

In terms of completing the form, information and guidance can be found here – FCA Handbook – SUP16.23 Annual Financial Crime Report and SUP 16 Annex 42B Guidance notes – Annual Financial Crime Report

How we can help

Neopay can help by reviewing your overall compliance and regulatory framework to ensure that your business complies with the regulatory requirements. We can help you identify gaps or weakness in your financial crime systems and controls, and provide remediation steps to resolve any areas of non-compliance, through our range of targeted audits.

If you’d like to know more about how we can assist you with your policies and procedures and ensure your framework is compliant, or any other regulatory compliance matters, please contact our specialist team here.

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