The FSA is applying considerable supervisory effort and focus on Senior Management Systems and Controls (SYSC) and now we have at least two examples of enforcement action against firms that cannot demonstrate effective controls.

In the last month we have been contacted by two new firms as they are facing regulatory enforcement measures for SYSC failures. Most firms had SYSC at the top of their agenda at the time of authorisation but it seems to have slipped down the agenda for many firms. May we suggest that firms refresh and renew their SYSC with a focus on TCF, suitability, financial crime.

On the financial crime front, the Joint Money Laundering Steering Group (JMLSG) has issued revised guidance but this paper is for consultation not action. However, there will be revised guidance in the future so please watch this space.

For a quick and interesting read, the ABI ‘Key Facts 2009’ is worth a look as it is a good and succinct Annual Report and demonstrates the importance of Intermediaries as 96% of long term insurance sales were generated by this sector.

If we can help with these or any other regulatory matters, please remember your helpline 08456 121211 or email admin@ifact.co.uk for a without obligation conversation.

Kind regards

John Derry-Collins
FInst SM AMITD Fcol MInstD MIoD
Director
IFAct Services Ltd
Tel. No. 08456 121 211

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QBE Insurance (Europe) Limited “QIE” (No. 1761561) is authorised and regulated by the Financial Services Authority. Ensign is a trading name of QIE. Limit Underwriting Limited “LUL” (No. 1035198) is a managing agent for Syndicates at Lloyd’s and is authorised and regulated by the Financial Services Authority. DA Constable Syndicate Limited (No. 2262145) and Limit Technology & Commercial Underwriting Limited “LTCUL” (No. 3515409) are appointed representatives of LUL. Icon Insurance and Praemunio are trading names of LTCUL. QBE Management (UK) Limited (No. 3153567) is a service company and QBE International Holdings (UK) PLC (No. 2641728) is the holding company for QBE European Operations, a division of the QBE Insurance Group. The above companies are registered in England and Wales at Plantation Place, 30 Fenchurch Street, London EC3M 3BD. QBE Reinsurance (Europe) Limited (No. 53272) is registered in the Republic of Ireland at St. Stephen's Green House, Earlsfort Terrace, Dublin 2.

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