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  • FC-2.1 FC-2.1 General Requirements

    • FC-2.1.1

      Investment firm licensees must implement programmes against money laundering and terrorist financing which establish and maintain appropriate systems and controls for compliance with the requirements of this Module and which limit their vulnerability to financial crime. These systems and controls must be documented, and approved and reviewed annually by the Board of the licensee. The documentation, and the Board's review and approval, must be made available upon request to the CBB.

      Amended: October 2014
      Amended: January 2007

    • FC-2.1.2

      The above systems and controls, and associated documented policies and procedures, should cover standards for customer acceptance, on-going monitoring of high-risk accounts, staff training and adequate screening procedures to ensure high standards when hiring employees.

    • FC-2.1.3

      Investment firm licensees must incorporate Key Performance Indicators (KPIs) to ensure compliance with AML/CFT requirements by all staff. The performance against the KPIs must be adequately reflected in their annual performance evaluation and in their remuneration (See also Paragraph HC-5.3.3).

      Added: April 2020

    • FC-2.1.4

      In implementing the policies, procedures and monitoring tools for ensuring compliance with Paragraph FC-2.1.3, investment firm licensees should consider the following:

      (a) The business policies and practices should be designed to reduce incentives for staff to expose the investment firm licensees to AML/CFT compliance risk;
      (b) The performance measures of departments/divisions/units and personnel should include measures to address AML/CFT compliance obligations;
      (c) AML/CFT compliance breaches and deficiencies should be attributed to the relevant departments/divisions/units and personnel within the organisation as appropriate;
      (d) Remuneration and bonuses should be adjusted for AML/CFT compliance breaches and deficiencies; and
      (e) Both quantitative measures and human judgement should play a role in determining any adjustments to the remuneration and bonuses resulting from the above.
      Added: April 2020