On 10 June 2019, the Financial Conduct Authority (“FCA”) published a report (the “Report”) following its Thematic Review of the money laundering risks in the capital markets. The review involved 19 participants covering different segments of the market. Although the review was broad in terms of the participants, which included investment banks, custodian banks, inter-dealer brokers, and clearing houses, it did not include assessment of the participants’ systems and controls. This alert highlights some of the key findings from the Report, and seeks to extrapolate points of practical guidance that may arise out of it.
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