FCA publishes guidance on reporting sanctions evasion by regulated firms
The Financial Conduct Authority (FCA) has published guidance outlining how to report suspected sanctions evasion, establishing three reporting channels for submitting information about firms listed on the Financial Services Register or companies with UK listed securities. The guidance specifies that confidential reports concerning current or previous employers should be directed to the FCA's Whistleblowing team, while authorised firms reporting issues within their own firm without requiring anonymity should follow Sup 15 procedures. Firms or professionals with information about potential or actual sanctions evasion by other firms or individuals should use the FCA's reporting form for wrongdoing or misconduct. The FCA seeks information on inadequate sanctions controls, suspected or actual breaches of the sanctions regime and methods used to circumvent sanctions requirements. The guidance also clarifies that reporting to the FCA does not replace statutory legal requirements under the Proceeds of Crime Act 2002 or the Sanctions and Anti-Money Laundering Act 2018. Firms operating in sectors overseen by other regulators are advised to notify their relevant supervisory authority in addition to the FCA.