The FCA has published a report summarising the results of its thematic review into banks’ control of financial crime risk in trade finance. The report highlights areas of common weakness between the banks visited and also sets out examples of good and poor practice. It covers the following areas: governance and management information, risk assessment, policies and procedures, due diligence, training and awareness, money laundering controls, terrorist financing controls, and sanction controls including in relation to financing dual use goods. The main conclusion of the report is that the majority of banks in the sample, including a number of major UK banks, are not taking adequate measures to mitigate the risk of money laundering and terrorist financing in their trade finance business.

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