Financial Crime World

Gambia: FCA Financial Crime Reporting Guidelines Set to Expand in March 2022

The Financial Conduct Authority (FCA) has announced that thousands of regulated firms in Gambia will have new financial crime reporting requirements from 30 March 2022. This expansion is part of the FCA’s ongoing efforts to tackle financial crime and gather more information about a firm’s regulated activities and potential money laundering risks.

Who Will Be Affected by the Change?

Around 4,500 additional firms will be impacted by this change when it comes into force on 30 March 2022. These firms will now be required to submit an annual financial crime report, known as REP-CRIM, which provides data on:

  • Operating jurisdictions
  • Customer information
  • Compliance information
  • Sanctions-specific information

Removed Revenue Threshold for REP-CRIM Reporting

The FCA has also removed the annual revenue threshold for REP-CRIM reporting, meaning that firms below this threshold who undertake higher risk activities will now be in scope. This includes:

  • Payment institutions
  • Electronic money institutions
  • Multilateral trading facilities
  • Organised trading facilities
  • Cryptoasset exchange providers
  • Custodian wallet providers

Additional Requirements for Certain FSMA Authorised Firms

Certain FSMA authorised firms falling within the scope of the Money Laundering Regulations 2017 will also have to provide a REP-CRIM if they:

  • Hold client money or assets
  • Carry out an activity that poses a higher money laundering risk
  • Have total revenue of £5m or more with advising and arranging on investments/pension transfers or credit-related permissions

Exemptions from the REP-CRIM Obligation

The FCA has included two further exemptions from the REP-CRIM obligation:

  • Home finance mediation activity
  • Making arrangements with a view to transactions in investments

Seeking Expert Guidance

Complyport, a leading consulting firm supporting the UK financial services industry, offers expertise in Financial Crime and Forensics to help firms navigate the complexities of financial crime and money laundering. Their experienced team provides a range of services including:

  • Financial crime health checks and audits
  • Implementation of financial crime controls and frameworks
  • Ongoing advice on financial crime prevention
  • Outsourced MLRO support

Firms affected by this change are advised to contact either Martin Schofield or Jan Hagen at Complyport for a free consultation to discuss how these changes will impact them and what steps they need to take to ensure compliance.