On 1 December, it was announced that the UK Office of Financial Sanctions Implementation (“OFSI”) and the UK Financial Conduct Authority (“FCA”) had entered into a memorandum of understanding (“MOU”) on 21 November 2023 which outlines the agencies’ agreement to co-operate and share information relating to suspected or actual sanctions breaches with each other. This MOU replaces a previous MOU that had been in place since April 2019. In summary, under the MOU it has…
On 9 September the Financial Conduct Authority (“FCA”) and the Prudential Regulation Authority (“PRA”) published a letter to bank CEOs with the purpose of reiterating expectations of firms when undertaking trade finance activities. The Dear CEO letter addressed both conduct and prudential issues where the regulators consider that improvements are required in firms’ controls. The regulators stressed that “firms need to demonstrate that they have taken a risk sensitive approach to their control environment that…