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P2 FinCrime is built on the foundations of P2 Consulting and FS 101, both challengers in their respective markets. By combining the Financial Crime expertise of the FS 101 team with the project and programme management skills of P2 consulting we offer the best solutions to clients without the Big 4 overheads.

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P2 FinCrime’s services span the regulatory change lifecycle for Financial Institutions – from advisory and operating model design, to systems evaluation and implementation with a heavy dose of operational performance improvement and remediation along the way.


Understanding the challenges that keep our clients awake at night is essential. In this section we demonstrate our expertise at solving your problems. We have deep insight into the business and technology issues facing all sectors.

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In the first of our ‘Ask the Expert’ series, Phil Rolfe, P2 Consulting’s CEO, interviews financial crime and compliance expert Peter Hazlewood.

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FCA warns UK financial institutions of UBO adherence

P2 FinCrime’s Head of Transformation, Alastair Lauder


Alastair Lauder, Head of Transformation, P2 FinCrime

Following the start of the Ukrainian crisis, the FCA sent letters to all UK financial institutions, warning them the new Economic Bill will be fast-tracked. This bill includes a new register meaning foreign owners of UK property must declare and verify their identities with Companies House. The aim is to stop overseas criminals and oligarchs from using agents to create companies or buy property for them in the UK. Entities that refuse to declare their owners will face restrictions in selling property and those who break the rule could be imprisoned for up to five years.

The underlying issue is that certain Russian businesspeople have long used corporate structures in the UK to over dubious dealings or misbegotten gains and the UK’s financial system has – unfortunately – been vulnerable to money launderers.

This is the FCA’s attempt to put an end to Russian criminals using the British financial system to their advantage and this heart-breaking crisis has given the FCA the impetus to speed things up. Obviously, time is off the essence – the longer it takes to implement, the more time sanctioned Russians will have to offload assets making it difficult for the UK government to stop them profiting from these transactions.

So what can financial institutions do quickly?

The ability to track and trace Ultimate Beneficial Owners (UBOs) – the individuals who are the beneficiaries when a corporate transaction is made – is key. In its letter, the FCA stipulated that all financial institutions must have the appropriate checks and balances in place to track and trace to do this. And it’s vital that UBO identification and processes are not just box ticking exercises – that they are genuine attempts to identify these individuals meaning they can subject to sanctions.

Financial institutions also need to tighten up on KYB (know your business), the FCA’s corporate equivalent of KYC (know your customer) the AML and sanction regulation that has been in place in the UK for some considerable time now. The FCA will want to know UBO information – the corporate structure of the organisation financial institutions are dealing with, who is on the board and who is the beneficiary of any transaction that business might make.

The message is that financial institutions need to get their houses in order where it comes to dealing with Russian clients and they need to do it quick sharp. The consequences if they don’t won’t just be financial in the way of fines – they’ll take a massive reputational hit too, because as the Ukraine crisis worsens, corporations who deal with Russia will become pariahs.

If you’d like to chat to P2 Fincrime about how to approach the tricky issue of sanctions regulation at your organisation, , please email me at alastair.lauder@p2consulting.com or call +44 (0) 7425 160 549.

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