Michael Douglas

We’ve fined Monzo Bank Ltd £21,091,300 for its inadequate anti-financial crime systems and controls between October 2018 and August 2020. Monzo also repeatedly breached a requirement preventing it from opening accounts for high-risk customers between August 2020 and June 2022. Banks are a vital line of defence in the collective fight against financial crime. We’ll continue to supervise firms to improve standards and ensure they have the right systems and controls to manage financial crime risks. https://lnkd.in/e--xCDzG #FightingFinancialCrime #FinancialServices #FinancialRegulation

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It was a privilege to discuss #PaybyBank and the National Payments Vision with Roisin Edwards HM Treasury (author of the NPV) and Christopher Owen British Retail Consortium yesterday, excellently chaired by Tony Craddock from The Payments Association. Key discussion points: 👉🏻 industry is coalescing around PaybyBank as the consumer facing name for 'account to account payments powered by open banking'. Keep it simple for consumers - describe what they will do when they select the payment method. Not Pay by Card - Pay by Bank' 👉🏻this is not exactly the same as a brand - brands usually have central scheme management, PaybyBank / open banking is de-centalised currently - but is moving towards a possible scheme. This makes consideration of a brand possible. 👉🏻 the BRC (representing merchants) Broadly supports the NPV - because it points towards more payment choice and competition. Ultimately lower cost for merchants. 👉🏻 User experience needs to be a focus. Bank screens are not good enough. This needs to be solved with a combination of FCA supervision and commercial incentives. 👉🏻Recurring payments is the hero functionality that can level the playing field with card and create the choice highlighted in the NPV. The current blocker is arbitrary, it's technically possible today. Growth is round the corner as soon as we unlock VRP 🚀 Thanks to City & Financial Global for hosting an excellent day. #PaybyBank #VRP #nationalpaymentsvision

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If you ever question why collaboration pays, look at this result: advocacy groups from the #payments industry including UK Finance and The Payments Association have prevented well-meaning but disproportionate regulators from imposing 'creative' but what would have been seriously damaging changes to safeguarding regulations in the UK. The team at Travers Smith led by Natalie Lewis and Matt Humphreys highlight this outcome in their article, explaining how the changes being made will mean EMIs and PIs can continue to compete on a level playing field. World class collaboration. Riccardo Tordera-Ricchi Robert Courtneidge Mitch (Munish) Trehan Neil Harris Jana Mackintosh Nuala Jackson Sophie Boissier Ben Agnew Tom Brewin https://lnkd.in/evjedX7H

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The FCA has set out its strategy for the next 5 years and has identified 4 main priorities... 💡 Be a smarter regulator 📈 Support economic growth 💰 Help consumers navigate their financial lives 👮‍♀️ Fight financial crime Nikhil Rathi, CEO of the FCA, explained: "Our 4 priorities reinforce one another and we look forward to collaborating with our partners as we become a smarter regulator, support growth, help consumers and fight crime. "We are ambitious for the future and committed to enabling a fair and thriving financial services market for the good of consumers and the economy." As part of the strategy, the regulator has said it will invest in its technology, people and systems to better handle work load and also digitise and simplify the authorisation process. With financial services playing such a key part in the UK economy, it will be interesting to see what changes are implemented to power growth and support consumers!

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Ok, so the UK Home Office and HM Treasury published the UK's 2025 National Risk Assessment (NRA) for Money Laundering and Terrorist Financing yesterday. There are a few key points that our clients should be aware of, particularly those operating in the electronic money and payments sector. 📜 Financial Crime risk assessments: the Financial Conduct Authority expects firms it regulates or supervises to pay attention to the NRA when creating and maintaining business-wide and customer-specific financial crime risk assessments. Refer to the FCA's Financial Crime Guide (also recently updated) at paragraph 3.2.3. Accordingly, if you're an MLRO or on the board of a regulated or supervised firm, this might be a good time to do this / check that this has been done. 💷 Typologies: the NRA includes an updated assessment of typologies that have been sighted in each sector. Many are old, but there are a few new entrants. Ensure that your risk assessments account for these. Furthermore, determine whether your monitoring systems (manual or technological) sufficiently consider these typologies and whether calibrations remain adequate. 🎯 Prepare for possible regulatory interaction, especially if your firm is in the payments or electronic money space: the NRA reports a 231% increase in money laundering-related FCA supervisory activity involving these firms between 2020-24. Could your firm be next? Are you confident that your firm could demonstrate a robust control environment if inspected by the regulator? 🏦 The intersection between payment/electronic money services and cryptoasset activities is a key area of focus for UK authorities. The issuance of virtual IBANs is also attracting considerable scrutiny. If your firm is involved in these activities, it is likely to be very high on the radar for interaction. If you are seeking to launch a new firm or business line(s) in these areas, expect this to receive a lot of attention during the application process. These are just a few bits that I believe to be significant. If you'd like to read the full report, see here 👇 https://lnkd.in/eh8V4dfw #compliance #aml #amlcompliance #financialservices #financialmarkets #cryptoassets #payments

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