Financial Crime
Fighting financial crime is a priority for regulators, authorities and governments globally.
Over the last few years, the Financial Services Authority (FSA) and other regulators have taken a tougher stance with financial institutions for breach of financial crime regulations.
Such breaches are costly - both financially and for the institution’s reputation. We expect the environment to remain demanding or to become still more challenging.
Bribery and corruption and sanctions are particular areas where we have seen enforcement action increase. The UK Bribery Act and Wire Transfer Regulations have introduced additional requirements and risks.
Prosecutors in the US have levied large fines on UK institutions for breaches of economic sanctions. Lapses increasingly attract penalties outside the UK. The US Foreign Account Tax Compliance Act will impose further risks when it comes into force.
In June 2011 the FSA published Financial Crime: A Guide for Firms, which consolidated its views on what firms should do to prevent crime. The regulator highlighted inadequate anti-money laundering (AML) measures that have triggered enforcement action against banks and warned that many firms had weak measures to combat mortgage fraud.
The FSA is also developing a Core Financial Crime Programme focused on AML, terrorist finance and sanctions. The Financial Conduct Authority will maintain the FSA’s intensive and intrusive approach when it takes over enforcement powers in 2013.
Financial institutions are particularly exposed to financial crime due to the nature of their businesses and the volume of transactions and client relationships they manage.
Navigating regulations in areas such as sanctions, money laundering, bribery and corruption and fraud can be complex. Global financial institutions face even greater complexities with multiple legal and regulatory requirements in the UK, US and other countries where they do business.
The Deloitte approach to financial crime
Deloitte financial crime specialists come from a variety of industry, investigative, law enforcement, regulatory and technology backgrounds.
We have significant experience in assisting financial institutions on financial crime matters including:
- Proactive assistance around policy and governance, controls assessment, technology solutions and due diligence assignments.
- Reactive assistance around investigations and remediation.
We have regulatory expertise and experience of working with the FSA and other international regulators. Furthermore, as a network of member firms, we can work at both a global and local level which is a prerequisite for dealing with the sophisticated international networks used by criminals, terrorists and fraudsters.
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