Laura WilesThe SFO has charged United Insurance Brokers Limited with failing to prevent its US based intermediaries from bribing Ecuadorian state officials. The alleged activities happened between 2013 and 2016 and relate to...
Category - Financial Crime Prevention
Emma Radmore
OFSI publishes property services threat assessment
OFSI has published its latest “threat assessment” for the property and related services sector. The assessment, an update of the 2022 assessment, is relevant to all firms and sole practitioners involved in...
Companies House changes – get ready for identity verification
We’ve written this article on the identity verification reforms being introduced under the Economic Crime and Corporate Transparency Act 2023.
Ella MarshPSR defers APP claims management system consultation
The PSR had planned to consult in April 2025 on adopting Reporting Standard B and whether to put in place regulatory requirements for Pay.UK’s reimbursement claims management system. Having considered stakeholder...
FCA publishes work programme 2025-6
The FCA has published its work programme for 2025-26, which builds on the 4 priority areas in its 5 year plan. Specific initiatives additional to those set out in the 5 year plan (which we summarised in this article)...
OFSI publishes financial sanctions guidance for insolvency practitioners
The Office of Financial Sanctions Implementation (OFSI) has published guidance on financial sanctions aimed at insolvency practitioners and firms. The publication comes after insolvency practitioners have been added to...
FCA updates cash-based money laundering webpage
The FCA has updated its webpage on cash-based money laundering, which sets out the regulator’s recent work on reducing money laundering through cash deposits via the Post Office, and its expectations of...
APPG on Fair Banking publishes APP fraud report
The All Party Parliamentary Group (APPG) on Fair Banking has published a report on APP fraud, considering its scale and impact, and the effectiveness of associated regulation. The report concludes that while significant...
OFSI publishes financial sanctions guidance for letting agents
The Office of Financial Sanctions Implementation (OFSI) has published guidance on financial sanctions aimed at letting agents. The publication comes after letting agents have been added to the list of “relevant...
NCA publishes annual SARs report
The NCA has published its annual report on suspicious activity reports (SARs), covering April 2023 – March 2024. The report shows a 1.5% increase in the total number of SARs (872,048) compared to the previous year...
Treasury updates high risk third country notice
HM Treasury has updated its high risk third country advisory notice in line with the changes announced by FATF at its last plenary session. As a reminder, the FATF changes now apply as soon as announced by FATF, so have...
UK Finance publishes proliferation finance paper
UK Finance has published a paper that looks at risk management of proliferation finance risks by financial institutions. The guide looks at proliferation finance standards and regulatory frameworks in the UK and...
FCA publishes 5 year strategy
The FCA has launched its much-trailed 5 year strategy. It will focus on 4 priorities: being a smarter regulator; supporting sustained economic growth; helping consumers to navigate their financial lives; and fighting...
OFSI annual review shows £25bn frozen Russian assets
The OFSI annual review for 2023-4 shows that as of March 2024, the UK Government had designated over 2,000 entities and individuals under the Russia sanctions regime and frozen £25bn worth of Russian assets. It...
Companies House launches Authorised Corporate Service Provider registration service
On 18 March 2025, Companies House launched a new service enabling eligible third-party corporate service providers to apply to register as an Authorised Corporate Service Provider (ACSP). This initiative aims to enhance...
FCA refuses crypto-application on harm basis
The FCA has published its decision notice explaining why it has refused the application of Zeux Limited for registration as a crypto firm under the MLRs. The firm submitted its application in 2022. The FCA decided that...
Chancellor unveils more red tape cutting
The Chancellor has unveiled more detail of the plans to cut the administrative cost of regulation on business, at a meeting attended by, among others, the PRA, FCA and ICO. The plans are wide ranging across all areas of...
More ECCTA provisions take effect
The 4th Commencement Order for the Economic Crime and Corporate Transparency Act 2023 brings into force: on 18 March, the remainder of the provisions on the procedure for verifying identity, authorisation of corporate...
FCA consults on removing contactless limit
The FCA is asking for views on whether it would be a good thing to remove the contactless limit, and has published an “engagement paper” to seek views. The suggestion is all part of the work to support...
Treasury publishes AML/CFT supervision report
Treasury has published its supervision report 2023-4 for AML and CFT – the 12th report in all. The report is wider-ranging than previous years, including things like metrics on guidance and training that...
OFSI updates sanctions FAQs
OFSI has updated its UK financial sanctions FAQs with 13 new questions about what “relevant firms” need to do to comply with their reporting obligations. The questions include answers on how the obligations...
PSR updates on scam data publication plans
The PSR has outlined how it plans to publish APP scam data for 2024. Before the mandatory reimbursement requirement came into force in October, it published data annually. For the last cycle of 2024, it is planning to...
Artis Finance becomes latest non-bank lender to enter administration
Artis Finance Limited has become the latest non-bank trade finance outfit to enter administration. James Cameron, Tom Crookham and Edward Macnamara of PwC were appointed joint administrators of the London finance...
Amy GallimoreFCA bans ex-CS directors after US Mozambique convictions
The FCA has banned Andrew Pearse and Surjan Singh, former managing directors of Credi Suisse, following a US court convicting them of arranging corrupt loans to the Republic of Mozambique. The individuals had pleaded...
FCA starts criminal proceedings against 2 individuals
The FCA has started criminal proceedings against Kerry Nelson, former director of Nexus Independent Financial Advisers Limited and Nexus Investment Managers Limited and Jacqueline Stephens, business operations manager...
Individual jailed for 4 years for illegal crypto ATM operation
Olumide Osunkoya, who operated crypto ATMs at 28 locations through his company, Gidiplus Limited, while not being FCA registered to do so, has been jailed for 4 years. The FCA had refused Gidiplus’ application for...
FATF consults on PF and sanctions evasion project
The FATF is carrying out a study to improve country and private sector understanding of current proliferation financing risks and its looking to set out evasion techniques that those who seek to evade the targeted...
FATF updates standards and consults on financial inclusion
The FATF has published an updated version of its standards, which now better support financial inclusion. It has updated standard 1, and the interpretative notes to standards 1, 10 and 15 and its Glossary definitions...
FCA sets out asset management and alternatives supervisory priorities
The FCA has published its portfolio supervision letter sent to the asset management and alternatives sector. It notes five priority areas: supporting confident investing in private markets: the FCA sees increasing...
Michael LewisFATF consults on Recommendation 16
The FATF has published a second consultation on changes to Recommendation 16 on payment transparency and the related guidance and glossary terms. It needs to make the update to adapt the standard to changes in payment...
John Dance trial date set
John Dance, the former principal partner in the WealthTek LLP was charged in December 2024 with alleged misappropriation of customer funds totalling around £64m between 2014 and 2023. The trial date has now been listed...
FATF plenary outcomes
At the February FATF plenary meeting, it: updated the list of high risk jurisdictions, to add Lao People’s Democratic Republic and Nepal, and remove the Philippines from increased monitoring; agreed changes to its...
FCA publishes skilled persons data for Q2 / Q3 2024
In the quarter ending September 2024, the FCA commissioned 14 skilled persons reports: 6 reports related to consumer investments, 2 to insurance, 2 to wholesale markets (buy-side) and 4 to wholesale markets (sell-side);...
Wolfsberg Group publishes digital asset FAQs
The Wolfsberg Group has published a set of FAQs on how members conceive of and conceptualise key terms associated with digital assets. It says the guide will be a reference point for its future work on the risks of and...
Wolfsberg Group publishes payment transparency guidance
The Wolfsberg Group has published guidance on roles and responsibilities in payment transparency. Its guidance looks at the roles of the various actors in the payment chain and their respective responsibilities, using a...
FCA fines Mako in cum-ex trading investigations
The FCA has fined Mako Financial Markets Partnership LLP £1,662,700 for financial crime systems and controls failures. The firm had also failed to adequately apply policies and procedures it did have in place. The case...
OFSI publishes Financial Services Threat Assessment
The latest of OFSI’s Threat Assessment Reports focuses on financial services. The report is aimed at helping UK businesses to prioritise the highest risks in their approach to financial sanctions compliance. It...
Stenn fintech collapse – what’s happened so far
Recent updates from Stenn’s administrators have cast light on the hasty demise of the London-based fintech business, which continues to generate considerable interest. Kristina Kicks, Joshua Dwyer and James Tucker...
Foreign Affairs Committee seeks views on sanctions strategy
The Foreign Affairs Committee has opened an inquiry on the UK’s sanctions strategy, and it asking for written evidence on questions such as whether Parliament should have greater oversight of the UK sanctions...
PSR reflects on next steps for APP scam reimbursement
The PSR’s head of policy, Kate Fitzgerald, has blogged on what the PSR plans now that the main APP scam reimbursement requirement is in full effect. Its key priority relates to Pay.UK’s reimbursement claims...
FCA updates crypto-registration stats
The FCA received 2 new applications from crypto firms for registration under the MLRs in the past month. It also registered one firm, bringing the total registered since January 2020 to 50 – still only 14% of...
UK Finance publishes FTP fraud guidance
UK Finance has published guidance for the financial services sector on the failure to prevent fraud offence, which takes effect in September. The guidance cannot have statutory force or Government blessing, as the ECCTA...
FCA 2024 fin proms data shows increased action against misleading adverts
The FCA’s latest financial promotions data shows 19,766 promotions were amended or withdrawn in 2024, almost doubling the 2023 figure of 10,008. In previous reporting, the FCA acknowledged this sharp increase was...
Check out our newly updated Corporate timeline for 2025
We have launched our recently updated Corporate timeline for 2025 on the Womble Bond Dickinson website. The timeline covers key legislation and legal developments in both corporate and company law from January 2025...
JMLSG consults on Part 1 amendments
The JMLSG is consulting on changes to various parts of Part 1 of its guidance. The changes relate to: in chapter 5 new provisions on local authorities and professional deputies appointed by the Court of Protection or...
PSR and BoE agree next steps in CHAPs co-ordination
The PSR and BoE have published correspondence between them setting out how they intend to continue to work together on the CHAPS reimbursement requirement. The PSR does not have powers under the Financial Services...
FCA outlines wholesale broker supervision strategy
The FCA has published a Dear CEO letter to wholesale brokers, setting out its new supervision strategy for firms. In the last 2 years, the FCA has engaged with firms on issues including risk management, financial crime...
FCA settles care home investment scheme claim against solicitors
The FCA has settled a claim against solicitors Lupton Fawcett LLP in respect of work undertaken for the Qualia Group by a former member of the firm. The FCA previously brought a successful claim in the High Court...
FOS anticipates 37,000 fraud and scams complaints next financial year
The FOS expects fraud and scams to account for 35% – or 37,000 – of incoming banking and loan complaints in the coming financial year. This is an increase on the 33,000 fraud and scams cases it forecast to...
FCA reports on firms’ use of the NFD and money mules
The FCA has shared its findings from its review of payment service and account providers’ use of the National Fraud Database (a cross-sector database hosted by Cifas) and a money mule account detection tool. The...
FCA finds gaps in wholesale broker AML controls
The FCA has carried out a review on the systems and controls against money laundering that wholesale brokers have in place to prevent money laundering through the capital markets and has concluded that they could do...
Companies House confirms 2 ECCTA implementation dates
Companies House has confirmed that: from 25 February, it will be able to expedite striking off companies where the registrar concludes the company has been formed for a false basis and will be able to carry out checks...
OFSI and OFAC sign sanctions MoU
OFSI and OFAC have entered into a MoU (signed in October 2024) to help exchange of information and cooperation between the two bodies in administering and enforcing financial sanctions. The MoU sets out the desire for...
OFSI and OFAC sign MoU
HMT has published a MoU between the Office of Financial Sanctions Implementation (OFSI) and the United States Office of Foreign Assets Control (OFAC), to facilitate the exchange of information between the organisations...
FCA fines Arian Financial for failings relating to cum-ex trading
The FCA has fined Arian Financial LLP £288,962.53 for financial crime systems and controls failures. The firm’s failure to implement adequate measure put it at risk of being used to support fraudulent trading and...
FCA objects to Change in Control due to notification failures
The FCA has issued a final notice objecting to the proposed acquisition of Olampicaran Limited by Mr Ahmed, who had failed to notify and seek approval from the FCA. Olampicaran was a small payments firm providing money...
1 crypto registration approved last month
The FCA has updated its statistics on applications by crypto firms for registration under the MLRs. The latest stats show that 1 firm succeeded in becoming registered last month, while 2 applications were withdrawn...
UK designates extreme right wing group under sanctions legislation
The Government has designated “Blood and Honour” (and any aliases it uses) under the sanctions regime, imposing a full asset freeze on it with effect from 8 January. It says it has reasonable grounds to...
FCA executes search warrants in relation to unauthorised businesses
The FCA, in conjunction with the West Midlands Police, the Eastern Region Special Operations Unit and Police Scotland, has executed search warrants in two investigations involving unauthorised debt and claims management...
FCA issues Supervisory Notice to Hydrogard Legal Services
The FCA has published a First Supervisory Notice against Hydrogard Legal Services Limited, a firm with claims management permissions, requiring it to immediate cease carrying on all regulated activities other than with...
Regulators publish cyber findings for 2024
The BoE, PRA and FCA have published their latest annual CBEST thematic report. The report assesses the cyber resilience of key financial institutions through security testing performed in ‘live’ corporate...
FMSB publishes final client onboarding standard
The Financial Markets Standards Board (FMSB) has published its final Standard for Client Onboarding: Documentation and Processes. The Standard has been drafted to allow onboarding firms to continue to fully apply the...
FCA charges former WealthTek partner
The FCA has brought criminal charges against John Dance, the principal partner at WealthTek LLP, in relation to 9 criminal offences, including multiple counts of fraud and money laundering. WealthTek, then known as...
FCA updates Financial Crime Guide
Following a consultation, the FCA has made changes to its Financial Crime Guide. The changes cover the following areas: The FCA conducted extensive assessments of firms’ sanctions systems and controls following...
FOS notes huge increase in complaints
The latest figures from the FOS show complaints have increased by over 50%, with record increases in complaints about frauds and scams, current accounts and credit cards. The FOS also noted in particular an increasing...
FCA fines former Wizz Air executive for closed period trades and disclosure failures
The FCA has fined the former chief supply chain officer at Wizz Air Holdings plc £123,500 for trading company shares when he was not permitted to, and failing to disclose those trades. Between April 2019 and November...
FCA publishes research on crypto ownership
The latest FCA research on consumer attitudes and behaviours toward cryptoassets, 12% of UK adults now own crypto, up from 10% in previous findings. Other key findings included: Awareness of crypto rose from 91 to 93%...
FCA fines Macquarie Bank £13m for fictitious trades control failings
The FCA has fined Macquarie Bank Limited – London Branch £13m for serious control failures that allowed an employee to record over 400 fictitious trades. From June 2020 to February 2022, Travis Klein – based...
FCA updates payments and e-money Approach Document on “reasonable grounds” for delaying payment
Following a consultation, the FCA has updated its payment services and e-money Approach Document to support amendments to the PSRs made in the Payment Services (Amendment) Regulations 2024. The provisions came into...
Tribunal disagrees with FCA on fine amount
The FCA had found Arian Financial LLP had breached Principles 2 and 3 in respect of failings in its financial crime prevention systems and controls in relation to business introduced by the now infamous “Solo...
Treasury updates money laundering advisory
HM Treasury has updated its money laundering advisory notice in relation to high risk third countries. The update follows the FATF meeting on 25 October and reflects the list agreed (and which took effect) then.
FCA updates market cleanliness measures
The FCA has revised its methodology for its market cleanliness statistic, to make it more accurate. Going forwards it will be able to detect abnormal price movements that happen on the same day as an announcement, use a...
FCA reacts to Mansion House speech
The FCA has reacted to several announcements from the Mansion House speech. It has reiterated that it is committed to supporting growth and says it has fully embraced its secondary international competitiveness and...
Mansion House speech heralds 5 priority growth areas
The Chancellor’s first Mansion House speech stressed the importance of the financial services industry to the UK and highlighted 5 priority growth opportunities on which the Government will focus its strategy:...
FCA fines Metro Bank £16m for financial crime control failings
The FCA has fined Metro Bank PLC £16,675,200 for failures relating to the systems and controls it had in place to monitor transactions for money laundering risks. The period concerned spanned from June 2016 to December...
PSR writes to tech firms on fraud enabler data
The PSR has written to online, social media and tech firms, telling them of its upcoming report on firms which are most commonly reported as enabling contact between fraudsters and victims. The letter to the relevant...
The Economic Crime and Corporate Transparency Act: Companies House reveals implementation timetable for upcoming changes
Companies House published a policy paper on 16 October 2024 setting out an indicative timetable for the changes at Companies House which are still to be introduced by the Economic Crime and Corporate Transparency Act...
Suzanne GadoFATF publishes money laundering national risk assessment guidance
The FATF has published guidance on money laundering national risk assessments (NRAs). The guidance aims to support countries in conducting an NRA focussed on evaluating money laundering vulnerabilities. Key sections...
FCA convicts individuals for £1.5m investment fraud
The FCA has secured convictions against two individuals in relation to a £1.5m investment fraud. Between February 2017 and June 2019, Raymondip Bedi and Patrick Mavanga defrauded at least 65 investors by cold calling...
Failure to prevent fraud offence to take effect next September
The provisions of the Economic Crime and Corporate Transparency Act 2023 relating to the new offence of failure to prevent fraud that will apply to large companies will take effect from 1 September 2025. Off the back of...
OFSI updates sanctions FAQs
OFSI has updated its FAQs on financial sanctions. The main newly featured question addresses whether overseas subsidiaries of UK entities are expected to comply with UK sanctions – the answer being that the...
FCA updates crypto registration stats
The FCA’s monthly update of its statistics on applications for registration under the MLRs for cryptoasset firms shows that in the past month it has received 1 application, rejected 1, and 1 has been withdrawn. ...
CoP takes wider effect
From 31 October, the expanded roll out of Confirmation of Payee now means that 99% of all transactions made through Faster Payments and CHAPs are within scope, as the PSR’s SD17 took effect. The initial grouping...
FCA publishes lessons for operational resilience post-CrowdStrike
The FCA has published its observations and key lessons from how firms responded to the July 2024 CrowdStrike outage, and their preparedness to respond to future incidents. The FCA noted that it has seen a continuing...
SFO and CoLP work towards easier fraud reporting
The SFO and City of London police have advised that, with effect from 28 October, all fraud referrals that are not from companies or whistleblowers should be made to Action Fraud either online or via the call centre...
FATF holds October plenary
Key highlights from FATF’s October plenary meeting are: approval of the last 2 reports of the fourth assessment cycle; removal of Senegal from the high-risk monitoring list and addition of Algeria, Angola, Cote...
FCA publishes Q3 fin proms data
The FCA has published its financial promotions data for Q3 2024 on its actions against firms breaching financial promotion rules, and referrals and investigations into unregulated activity. During the period: 10,593...
FCA targets illegal finfluencers
The FCA is interviewing 20 “finfluencers” under caution in a targeted action against social media account holders which may be promoting financial services products illegally. It has also issued 38 alerts...
OFSI updates guidance
OFSI has updated its guidance on counter-terrorism sanctions. The guidance reflects recent updates to secondary legislation made under SAMLA (most recently the June update in relation to the director disqualification...
FATF updates grey list criteria
The FATF has updated the criteria for its “grey list“, which sets out jurisdictions under increased monitoring who are working with the FATF to address with agreed timeframes the strategic deficiencies in...
G7 Cyber Expert Group publishes guidance on combatting quantum computing risks in the financial sector
The G7 Cyber Expert Group (CEG) has published a statement highlighting potential cybersecurity risks arising from developments in quantum computing, and how these may be addressed by the financial sector. The CEG...
Payment Delay Regulations to take effect on 30 October
Treasury has made the Payment Services (Amendment) Regulations 2024. They will take effect on 30 October and amend regulation 86 of the PSRs that requires PSPs to execute payment transactions within set timeframes. The...
Market Watch focuses on SYSC 6 and UBOs
The latest edition of Market Watch looks at how firms can ensure compliance with SYSC 6.1.1R when dealing for overseas clients who operate aggregated accounts that provide no visibility of the UBOs. Firms will often...
FCA updates on crypto applications
During the month to 1 October 2024, the FCA received 4 new applications from firms seeking to register as crypto firms under the MLRs, making a total of 364 since January 2020. It registered one firm during the period...
FCA sets clear expectations on APP fraud reimbursement
The FCA has wasted no time. On the day the new reimbursement requirement for APP frauds using FPS or CHAPS took effect (7 October), it has written two Dear CEO letters, one to banks and building societies and one to...
Regulators herald APP scam reimbursement requirement
The PSR and other regulators have welcomed the effective date of the APP scam reimbursement requirement, applicable to payments made over FPS and CHAPS between UK bank accounts. The PSR stressed that: over 99% of claims...
ECCTA guidance on AML information sharing
The Department for Business and Trade has published guidance on the information sharing measures under the ECCTA 2023 for use by AML regulated firms. The guidance aims to help firms ensure that when they share...
Government finalises payment delay regulations
The final draft of the Payment Services (Amendment) Regulations 2024 confirms that PSPs can delay the execution of certain payment orders where the PSP establishes reasonable grounds to suspect the order has been made...
FCA fines Starling Bank £29m for financial crime control failings
The FCA has fined Starling Bank Limited approximately £29m for financial crime failings related to its financial sanctions screening process, and for repeatedly breaching a requirement not to open accounts for high-risk...
OPBAS calls for MLR supervision improvement
OPBAS says while most of the Professional Body Supervisors are complying with money laundering regulation, they are not consistently and effectively supervising their regulated communities. It says none of them are...
PSR confirms APP scam or civil dispute guidance
The PSR has confirmed its final guidance to help firms distinguish whether claims they receive from customers who have lost money are APP scams or more likely to be civil disputes. The guidance is aimed at helping firms...
UK Finance and LSB respond on proposed reduction to APP reimbursement cap
UK Finance and the LSB have responded to the PSR’s urgent consultation on lowering the maximum level of reimbursement for Faster Payments APP scams to £85,000, a significant reduction from the previously agreed...
FCA speaks on fraud prevention
Andrea Bowe of the FCA has spoken on what the FCA is doing to help reduce financial crime and its key role in the implementation of the Government’s Economic Crime Plan. She spoke of the equal importance of...