CP26/38: Financial Crime Guide Updates

The FCA has opened a consultation on changes to its Financial Crime Guide, intended to help firms assess and strengthen their financial crime systems and controls. The proposals draw on recent supervisory work and wider developments in the risk landscape.

Areas covered include fraud, reflecting lessons from multi-firm work; proliferation financing, where the FCA proposes fuller guidance on risks and controls; and expectations for firms using Banking-as-a-Service models, including outsourced, white-labelled and embedded finance arrangements. The updates also anticipate cryptoasset firms coming under FCA authorisation.

The Guide contains no new rules but sets out self-assessment questions and examples of good and poor practice. The consultation is relevant to all firms the FCA supervises for financial crime, including those supervised under the Money Laundering Regulations. Comments are due by 24 December 2026, after which the FCA will publish a Policy Statement with the final text.

Article Credit: https://www.fca.org.uk/publications/consultation-papers/cp26-38-financial-crime-guide-updates