FCA's expectations of "purposeful" AML systems and controls | Practical Law
In this article, Oliver Palmer, an Associate at Allen & Overy LLP, considers the speech given by Mark Steward, FCA Executive Director of Enforcement and Market Oversight, on 1 April 2021, on the importance of purposeful anti-money laundering (AML) controls. In particular, he considers what the FCA means by "purposeful" in this context, and what this adds to the existing FCA requirement for firms to establish "effective" AML systems and controls.