With increasing volatility in Afghanistan as UK and US troops withdraw, the FCA have issued a statement reminding firms that they should consider the possible impact these events may have on patterns of financial activity.
This is particularly relevant when assessing risks related to particular customers and the flows of funds.
The statement is a reminder of already existing rules requiring firms to minimise the risk that it will be used for the furtherance of financial crime, ensuring it takes a risk based approach and follows the rules and regulations as laid down, including undertaking appropriate due diligence.
Interestingly while there are a number of persons on the designated sanctions list within Afghanistan (and it is therefore unlawful to provide financial services to or for the benefit of these individuals), it is currently not listed as a high-risk jurisdiction in Schedule 3ZA of the Regulations.
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