Cunningham Lindsey UK

Financial Crime andMoney LaunderingRegulationOne of the FSA’s four statutory objectives is to reducefinancial crime for which they created a specialistdivision on 1 January 2007.Their handbook includes a requirement for effectiveSystems and Controls (3.2.6) to counter the risk thatfirms might be used as a vehicle for financial crime andgo on to recommend a compliance function withsufficiently independent staff to counter such activities.The FSA also expect a strategic approach to claimsfraud with adequate processes and controls in place todeal with financial crime in claims ranging fromexaggeration of loss to staged and fictitious incidents.The original Money Laundering section of the FSAHandbook has been replaced with a less prescriptiverisk based regime. Nevertheless, they make it clear thatan active response is still needed wherever MoneyLaundering poses a threat which includes claims.Cunningham Lindsey UK ResponseFSA requirements are not just aimed at fraudulentclaims but apply to internal fraud and wider issues,which we have addressed in different ways as follows:• We have an internal fraud policy with ‘whistle-blowing’facilities• We have an independent internal Product Assuranceteam which investigates any reported incidents andcontinually develops our anti-fraud strategy• We have a claims fraud strategy that uses proactivefraud detection systems and a variety of containmentmethods including conversation management and alarge network of dedicated special investigators.Measurement is used to demonstrate theeffectiveness of our approach• We have developed a money laundering policy in linewith FSAs risk based approach which addresses thebroad range of associated legislation and reportingrequirementsWe also provide many other anti-fraud servicesincluding an award winning anti-fraud campaign with a‘hotline’ service for the public to report any suspectedinsurance frauds. To promote this, we have created arange of provocative posters and leaflets, which can betailored to a particular organisations' needs.32 Cunningham Lindsey UK Financial Crime and Money Laundering 33