Principles for Doing Business at Lloyd's P11.3: 11.3 Systems and controls, including training, for regulatory responsibilities and financial crime risk

Systems and controls, including training, manage regulatory responsibilities and financial crime risk. Reporting and MI: prompt incident reporting to Lloyd's and UK authorities; immediate reporting to the Office of Financial Sanctions Implementation of any target match against the UK Consolidated List; notification to Lloyd's of suspected, potential or actual financial crime including suspicious activity reports; an annual financial crime report to the board or risk committee. Training: policies embedded through proportionate, tailored, accountable training setting out escalation, assessed for effectiveness, with annual mandatory training on the six risk areas at higher levels. Systems and controls: proportionate, risk-based controls including customer due diligence scaled to risk; documented policies with embedded escalation and remediation; a framework meeting the reasonable procedures test under UK law; oversight of third parties, which remain the managing agent's responsibility. Regulatory: underwriting guidance on writing business within Lloyd's licences using Lloyd's regulatory tools, escalation criteria for potential breaches, horizon scanning and regulatory training for all staff including onboarding. Business through Lloyd's Insurance Company (LIC) follows the LIC Financial Crime Requirements Guide.