We have all watched the tragedy evolve in Ukraine with great sadness and anxiety. It is therefore essential that we remain vigilant to ensure we are not a party to any financial crime that aids the conflict.
The FCA has recently published the below announcing the new financial sanctions against Russia. It is your regulatory responsibility to ensure you are strictly following the guidance.
The simple way to meet the requirements is to use the tool ‘sanction search’ to which you have discounted access as part of your Connect membership.
If you are using the case management team to process your applications, the team will complete the sanctions check on your behalf before the application is submitted.
If you are signed off for submitting your own applications, as part of this, you should have signed up with Sanctions Search or equivalent service and be performing these checks on every application before submission.
Money Laundering – Deposits
Tracking the source of funds used for a mortgage deposit is very important, particularly if funds are coming from offshore.
You should ideally take original evidence of deposit. If you receive a certified copy of the deposit, ensure you check the credentials and validity of the person certifying the document and that they did indeed complete the certification.
The original source of the deposit should still be considered for remortgages, particularly those where the purchase was within the last 6-12 months.
Also, check that the size of the deposit makes sense to the case. For example, if someone earning £20000 per year has a deposit of £150000 from savings, is this a plausible scenario? You will certainly need more information.
PI Excess increase
Due to the increased risk, from the renewal date of our Network PI policy on the 11th March, the excess for PI claims for non-UK residents purchasing in the UK is increasing to £20000. If you advise these types of clients, your cases will be reviewed to ensure you are applying the enhanced due diligence on them all, and we will also need to ensure you have the increased solvency requirement when we assess your annual fit and proper status.
Please speak with the compliance team if you have any queries on the matter or if you wish to report any suspicious case activity.