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My Lords, as one of those who drafted, or helped to draft, the anti-money laundering directives in Brussels—I emphasise that they were directives—I nevertheless have certain concerns about the way in which the Financial Conduct Authority has interpreted them, in particular the parts that offered proportionality in the application of regulation. A lot of small investors have suffered as a result of an overzealousness of the banking institutions sometimes to do things they do not need to do and to inquire in ways they do not need to inquire. Does my noble friend agree that proportionality should be deployed properly by the Financial Conduct Authority?
My Lords, as one of those who drafted, or helped to draft, the anti-money laundering directives in Brussels—I emphasise that they were directives—I nevertheless have certain concerns about the way in which the Financial Conduct Authority has interpreted them, in particular the parts that offered proportionality in the application of regulation. A lot of small investors have suffered as a result of an overzealousness of the banking institutions sometimes to do things they do not need to do and to inquire in ways they do not need to inquire. Does my noble friend agree that proportionality should be deployed properly by the Financial Conduct Authority?
I agree with my noble friend. We are straying away from the Home Office brief on this subject. Obviously, the Financial Services Act 2012 established the FCA as the conduct of business regulator for financial services. It has a focused set of objectives to promote effective competition in the interests of consumers, to secure an appropriate degree of protection for consumers and to protect and enhance the integrity of the UK financial system, but I absolutely agree that proportionality has to be a part of that.