Amendments to the Financial Conduct Authority handbook: Quarterly consultation paper 27

AAT welcomes the changes to the Decision Procedure and Penalties manual (DEPP) relating to the OPBAS Regulations. AAT recognises that establishing a consistent, robust anti-money laundering supervisory regime in the UK is paramount. These proposed changes will provide consistency in approach in relation to decision made under regulations 16 and 17 of the OPBAS regulations in line with the decision-making process currently followed in DEPP 3 and 4.

We welcome the FCA’s renewed focus on improving the process of referring cases from Supervision to Enforcement by making the Regulatory Decisions Committee (RDC) decision maker on enforcement decisions to make sure that such decisions are made consistently and fairly.

AAT agrees with the FCA decision to add the Institute of Financial Accountants (IFA) to the list of bodies whose members can make exemption for high net worth borrowers and hirers and exemption relating to businesses under the Consumer Credit sourcebook (CONC).