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The following posts provide a snapshot of selected UK, EU and global financial regulatory developments of interest to banks, investment firms, broker-dealers, market infrastructures, asset managers and corporates.
  • AMLA final draft RTS on pecuniary sanctions, administrative measures and periodic penalty payments
    8 July 2026

    The EU Authority for Anti-Money Laundering and Countering the Financing of Terrorism (AMLA) have published its final report with draft regulatory technical standards (RTS) under Article 53(10) of the sixth Anti-Money Laundering Directive (EU) 2024/1640 (AMLD 6). The RTS establish a framework for assessing the gravity of breaches, determining the level of pecuniary sanctions and administrative measures, and imposing periodic penalty payments (PePPs). They set out indicators for assessing breaches, classify breaches into four levels of severity, and establish criteria for determining sanctions and other measures. They also include provisions relating to natural persons, including senior management and supervisory board members, and procedural aspects for the imposition of PePPs.

    Following the February consultation, AMLA made targeted amendments, including clarifications on the application of the framework to non-financial sector firms, confirmation that category 3 and 4 breaches constitute "serious, repeated or systematic" breaches for the purposes of AMLD 6, and revisions allowing supervisors to rely on any reliable and relevant information when assessing breaches. The draft RTS will now be submitted to the European Commission for adoption before publication in the Official Journal of the EU.

  • AMLA draft ITS on common format for reporting suspicions under AMLR
    2 July 2026


    The EU Anti-Money Laundering Authority (AMLA) has launched a consultation on draft implementing technical standards (ITS) establishing a common EU-wide format for reporting suspicious transactions and activities under the Anti-Money Laundering Regulation (EU) 2024/1624. Currently, the way suspicions and transaction records are reported differs from one country to another. This makes it harder for companies operating across borders to know what is expected from them, and harder for Financial Intelligence Units (FIUs) to exchange information with each other and with their partners. The proposed ITS would introduce a harmonised set of data points and reporting templates for obliged entities, while allowing for sector-specific reporting requirements, with the aim of improving consistency across member states, reducing reporting complexity for cross-border firms, and enhancing information sharing and processing by FIUs. The deadline for responses is 20 September. A public hearing will be held on 9 September.

  • UK PSR independent review of APP reimbursement policy finds reduction in payment fraud
    1 July 2026

    The UK Payment Systems Regulator (PSR) has announced that its authorised push payment reimbursement policy is having a positive impact, according to the findings of an independent review. The findings show that payment fraud losses have fallen by GBP73 million per year, APP scam volumes have reduced by approximately 35,000 cases, reimbursement rates have increased from 54% to 65% overall (and to 97% for in-scope claims), and firms with historically higher fraud levels have made the most significant improvements.

    The PSR noted that there is no evidence of market exit or significant moral hazard, although some inconsistency in implementation remains across firms. To address this, the PSR has published a roadmap setting out its next steps. The regulator will also consult, before the end of the year, on measures to improve the application of the policy and will continue to monitor evolving fraud risks, including by publishing data on the platforms used by fraudsters to target victims.

  • UK OFSI and HMT publish insights from call for evidence on ownership and control
    30 June 2026


    The UK government has published a bulletin confirming initial insights from the earlier call for evidence on the ownership and control test under UK Financial Sanctions Regulations. The call for evidence sought input on the practical operation of the test and any particular challenges in implementing the requirements.

    Feedback provided the UK Office of Financial Sanctions Implementation (OFSI) with a clearer picture of how often questions of hypothetical control are raised in practice. The term hypothetical control refers to the aspect of the control test which asks the person applying the test to consider whether or not the potential controller would, if they so desired, be able (directly or indirectly) to direct the controlled entity's business as they wished. There is no requirement to demonstrate actual exercise of such hypothetical control for this aspect of the test, and it is notoriously difficult to apply in practice as it is a particularly broad and subjective area.

    Respondent feedback confirmed that they encountered challenges most frequently under the Russian sanctions regime and highlighted the cost and operational burden in making assessments based on limited information, requiring enhanced due diligence, legal advice, and delaying and/or escalating business decisions. Feedback also noted the limitations on the usefulness of existing tools and guidance which are not necessarily reliable in applying the test in practice.

    The bulletin confirms that this area of policy remains under ongoing review, and the government will continue to consider options for providing greater clarity.

  • AMLA advisory note on ML/TF risks as the MiCAR transitional period ends
    29 June 2026

    The EU Anti-Money Laundering Authority (AMLA) has issued an advisory note highlighting money laundering and terrorist financing (ML/TF) risks associated with the end of the transitional period under the Markets in Crypto-Assets Regulation (MiCAR). After 1 July, firms must be authorised as MiCAR-compliant crypto-asset service providers (CASPs) to continue providing crypto-asset services in the EU. The note outlines ML/TF risks arising from the end of the transitional period and identifies measures that can be taken by the crypto-asset sector, anti-money laundering and counter-terrorist financing supervisors, and financial intelligence units to ensure a coordinated and risk-based response that protects the integrity of the EU financial system. The note includes a table setting out the relevant risks and the corresponding suggested mitigation measures.

  • UK FCA Handbook Notice 142
    26 June 2026

    The UK Financial Conduct Authority (FCA) has published Handbook Notice No. 142 which covers changes on which the FCA consulted on (among other proposals) in its quarterly consultation paper No. 51 and its consultation CP25/37 on targeted clarifications of Handbook materials.

    The notice confirms the implementation of changes included in quarterly consultation paper No. 51 in relation to:

    • The UK equity transparency regime, which moved provisions from UK RTS 1 to MAR 11A.
    • The UK market abuse regime, where clarification has been made by introducing new provisions in MAR 1A.2 confirming where breaches of MAR do not give rise to a private right of action under section 138D of the Financial Services and Markets Act 2000.
    • The UK authorised fund regime, with changes to the COLL rules in line with amendments to the revised 2025 statement of recommended practice for authorised funds.


    Read more.

  • EBA consults on fines methodology and EC extends consultation deadline on MiCAR
    26 June 2026


    The European Banking Authority (EBA) has published a consultation paper setting out a draft methodology for the imposition of fines under the Markets in Crypto-Assets Regulation (MiCAR). The proposed framework is intended to ensure that fines imposed on issuers of significant asset-referenced tokens (ARTs) and e-money tokens (EMTs) are consistent, proportionate and transparent, and support effective compliance with the regime. Under MiCAR, the EBA is responsible for supervising issuers of tokens designated as significant, and the draft methodology outlines how fines may be calculated where infringements are committed negligently or intentionally by issuers or members of their management bodies. The deadline for comments is 28 September, with a public hearing scheduled for 16 July.

    Separately, the European Commission has announced it has extended the deadline for input to its consultation on EU crypto-asset rules by one month to 30 September.

  • FATF consults on guidance to increase payment transparency
    24 June 2026

    The Financial Action Task force (FATF) has launched a consultation on draft guidance to support the implementation of its revised Recommendation 16 (Wire transfers) on payment transparency. The Recommendation is commonly referred to as the "Travel Rule" and was updated in June 2025. The proposed guidance aims to reflect developments in the payments landscape and to strengthen the security of cross-border payments by increasing the transparency of information accompanying transfers and introducing measures to address fraud and errors. Feedback is sought on a range of issues, including:

    • Detecting and preventing misdirected payments, including by leveraging the three options for alignment checks foreseen in the revised Standard.
    • Implementation that supports financial inclusion, including in lower-capacity jurisdictions.
    • How Recommendation 16 applies to newer payment methods, such as digital wallets and mobile money.
    • Implementing Recommendation 16 and meeting data protection and privacy requirements together.
    The deadline for responses is 21 August, with the final guidance intended to assist jurisdictions and firms in meeting the revised standards by the end of 2030. The full list of consultation questions is set out in the explanatory memorandum to the draft guidance.
  • HMT consultation response on reform of UK's AML/CTF supervisory regime for professional services firms
    18 June 2026

    HM Treasury (HMT) has published its consultation response on the reform of the UK's anti-money laundering and counter-terrorist financing (AML/CTF) supervisory regime for professional services firms. This follows the decision announced last October that the UK Financial Conduct Authority (FCA) will be the sole AML supervisor for legal service providers, accountancy service providers and trust and company service providers under the Money Laundering Regulations 2017 (MLRs). A consultation, published in November 2025, set out the proposed key responsibilities and duties for the FCA's expanded role, along with the legislative changes needed to implement these reforms.

    The consultation response includes the policy decisions on these proposals, including:
    • Registration and gatekeeping. Making the FCA responsible for registering professional services firms carrying out AML/CTF regulated activity and for maintaining a public register of those firms. The FCA will also be given an explicit power to cancel a firm's registration where it is no longer carrying out regulated activity. In addition, the application of regulation 58 "fit and proper" requirements, enabling supervisors to assess the integrity, competence and compliance history of firms and their beneficial owners, officers and managers, will be extended across legal and accountancy service providers, aligning these sectors with trust and company service providers, which are already within scope.

    Read more.
  • UK FCA consults on changes to its penalty and decision-making policies
    15 June 2026

    The UK Financial Conduct Authority (FCA) has published consultation paper CP26/19, proposing targeted amendments to its Decision Procedure and Penalties Manual (DEPP) to ensure that its penalty framework and decision-making processes remain up-to-date, transparent and effective. The proposals also reflect the introduction of the market abuse regime for cryptoassets.

    Key proposals include:
    • Market abuse. Increasing the minimum initial disciplinary penalty level for serious market abuse committed by individuals from GBP100,000 to GBP150,000 to account for inflation.
    • Deterrence. Making clear that the FCA has the ability to increase penalties for wealthier individuals for deterrence, having regard to income and assets.
    • Relevant income. Clarifying how to treat deferred income, including bonuses, pay and shares, in line with recent Upper Tribunal decisions.

    Read more.
  • Companies House progress report on implementation of ECCTA 2023
    11 June 2026

    Companies House has published its third progress report on the implementation of reforms under Parts 1 to 3 of the Economic Crime and Corporate Transparency Act 2023. The report highlights progress in strengthening the integrity of the UK companies register and tackling economic crime, supported by increased data-sharing with HM Revenue & Customs and the Insolvency Service. This includes contributions to a National Crime Agency-led operation targeting high-street criminality and money laundering.

    The report also reflects progress in introducing mandatory identity verification (IDV) for directors and people with significant control, aimed at strengthening transparency and deterring those who use UK corporate structures to facilitate crime. Looking ahead, further measures are planned, including further IDV roll-out, enhanced transparency of the Register of Overseas Entities and a more intelligence-led enforcement approach. Annual progress reports will continue until 2030.
  • The Money Laundering and Terrorist Financing (Amendment) Regulations 2026
    9 June 2026

    The Money Laundering and Terrorist Financing (Amendment) Regulations 2026 have been made and laid before Parliament, alongside an explanatory memorandum. The Regulations make amendments to the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLRs) to implement the government's consultation response to its 2024 consultation on improving the effectiveness of the MLRs. The amendments aim to strengthen the UK's anti-money laundering and counter-terrorist financing regime and ensure continued compliance with Financial Action Task Force standards.

    Key changes include:
    • Refining due diligence requirements so that enhanced measures focus on higher risk transactions and jurisdictions.
    • Converting thresholds from EUR to GBP.
    • New provisions governing pooled client accounts.
    • Bringing the service of selling an off-the-shelf firm within scope of trust or company service provider services.
    • Strengthening the regime for cryptoasset businesses.
    • Changes to the scope of trust registration requirements.
    • Improving information-sharing between supervisory authorities and other regulatory bodies.

    Read more.
  • UK FCA and OFSI sign new MoU
    5 June 2026

    The UK Financial Conduct Authority has entered into a Memorandum of Understanding with the UK Office of Financial Sanctions Implementation. The MoU replaces an earlier MoU dated 21 November 2023 and sets out cooperation arrangements and exchange of information between the two regulators. The regulators commit to reviewing the effectiveness and efficiency of the MoU every two years.
  • AMLA consults on draft guidelines on ongoing monitoring of business relationships
    3 June 2026

    The EU Authority for Anti-Money Laundering and Countering the Financing of Terrorism (AMLA) has launched a consultation on draft guidelines on ongoing monitoring of business relationships under Article 26(5) of Regulation 2024/1624. The guidelines aim to ensure a proportionate, risk based and effective application of monitoring obligations across all obliged entities and set out key principles including:
    • Expectations for updating customer information through periodic and event driven reviews.
    • The sources of information that may be used alongside non exhaustive lists of factors to assess during periodic customer information reviews and event trigger reviews.
    • How monitoring frameworks should be designed and implemented to detect unusual or suspicious activity, using appropriate manual or automated controls.
    They further reflect the need for clear governance, adequate documentation, appropriate staff training, and the responsible use of advanced analytical tools, supported by effective human oversight, where appropriate. The deadline for comments is 3 September, with a public hearing scheduled for 2 July. Final guidelines are expected in Q4.
  • UK FCA Q&As on interaction between the MLRs 2017 and the new UK crypto regime
    2 June 2026

    The UK Financial Conduct Authority (FCA) has published Q&A responses from its 2026 webinar on the UK anti money laundering (AML) framework for cryptoasset firms. They clarify how the current Money Laundering Regulations 2017 (MLRs) will operate alongside the forthcoming cryptoasset regime under the Financial Services and Markets Act 2000 (Cryptoassets Regulations) 2026, which commences on 25 October 2027.

    Topics addressed include:
    • Applications under the Financial Services and Markets Act 2000 (FSMA) regime.
    • MLR registration will remain the route for firms providing in scope cryptoasset services until the new regime commences, but firms will need to obtain FSMA authorisation to continue operating under the new regime, with no automatic conversion. Current FSMA authorised firms must apply to vary their permissions if they wish to undertake the new cryptoasset regulated activities when the regime commences. Applications for the new regime will open on 30 September until 28 February 2027. Firms should consider the impact of when they submit their application. Firms are encouraged to prioritise securing FSMA authorisation over MLR-registration (with more guidance set out in an earlier webpage) and undertake early gap analyses against threshold conditions and proposed rules.

    Read more.
  • UK JMLSG consults on amendments to Part 1 of AML/CFT guidance
    1 June 2026

    The UK Joint Money Laundering Steering Group (JMLSG) has published a consultation on proposed amendments to Part I of its anti-money laundering and counter-terrorist financing (AML/CFT) guidance for the financial services sector. It reflects changes introduced by the draft Money Laundering and Terrorist Financing (Amendment) Regulations 2026 (as laid and not yet made) including:
    • Clarification of the term "unusually" in paragraph 2.9.
    • Introduction of a bank insolvency exception in paragraph 5.2.4A.
    • Updates relating to pooled client accounts in paragraph 5.3.142 and Annex 5 V.
    • Amendments concerning due diligence and verification of authority where a person acts on behalf of others in paragraphs 5.3.94A and 5.3.99.
    The deadline for comments is 29 June.
  • UK FCA publishes findings on sanctions systems and controls
    28 May 2026

    The UK Financial Conduct Authority (FCA) has set out guidance in a new report on compliance with the UK sanctions regimes. The FCA acknowledges that the rules on sanctions have become more complicated since February 2022.

    The FCA expects firms to understand when they could be engaging in activities which are at risk of causing sanctions breaches, for example:
    • Transferring funds out of accounts shortly after an individual or entity is sanctioned.
    • Accessing financial services or economic resources through complex ownership chains, relatives, or close associates.
    • Using third parties, intermediaries, or correspondent banks to obscure connections to a sanctioned person.
    • Routing funds through cryptoasset or e-money wallets to conceal links to designated persons.
    • Conducting cash withdrawals for onward movement to high-risk jurisdictions.
    • Mis-declaring the nature or end use of goods in trade transactions.
    • Providing falsified or incomplete trade documentation.

    Read more.
  • AMLA reporting package for selection of entities for direct supervision
    12 May 2026

    The EU Authority for Anti-Money Laundering and Countering the Financing of Terrorism (AMLA) has published a reporting package to support the identification of provisionally eligible obliged entities by national competent authorities (NCAs). This marks the next preparatory step for its first selection cycle of entities to be subject to direct supervision from 2028, following the conclusion of its data collection exercise to test and calibrate risk assessment models.

    The package, comprising a standardised reporting template and interpretative note for obliged entities, sets out instructions for NCAs to collect and submit the data required to determine which entities meet the criteria for selection in 2027. They will be responsible for collecting data by 15 August, followed by an error correction and alignment phase with home supervisors. A provisional list of eligible entities is expected to be finalised by the end of September. AMLA will host a public webinar on 10 June to offer eligible obliged entities (credit institutions, financial institutions, or their groups operating in at least six member states) a practical walkthrough of the template, with further information to follow.
  • AMLA consults on draft RTS for home-host supervisory cooperation
    11 May 2026

    The EU Authority for Anti-Money Laundering and Countering the Financing of Terrorism (AMLA) has launched a consultation on draft regulatory technical standards (RTS) under Article 46(4) of Directive (EU) 2024/1640 (MLD 6). The draft RTS specify the respective duties of home and host supervisors of cross-border groups of obliged entities operating in the financial and non-financial sectors, and the modalities of cooperation between them.

    Specific provisions in the draft RTS include:
    • Information exchange, including obligations to share information on the supervisor's own initiative and upon request, with specific content requirements.
    • Inquiries, setting out procedures for conducting or facilitating cross-border supervisory inquiries, including roles, timelines and post-inquiry exchanges.
    • Common approaches, enabling supervisors to, where necessary, agree on coordinated or joint supervisory activities.
    AMLA will hold a public hearing on 28 May for stakeholder input on the consultation.
  • UK FCA Market Watch 85—market conduct and transaction reporting issues
    29 April 2026

    The UK Financial Conduct Authority (FCA) has published Market Watch 85, setting out how the information‑sharing provisions in the Economic Crime and Corporate Transparency Act 2023 (ECCTA) can be used by firms to prevent, detect and investigate economic crime, including criminal market abuse. The FCA explains that ECCTA allows in-scope firms to share customer or former customer information with other firms directly where specified "warning" or "request" conditions are met, while providing protection from breaches of confidentiality and civil liability, subject to continued compliance with data protection requirements. The warning condition applies where a firm has taken (or would have taken) safeguarding action, such as terminating or restricting the service provided to a customer, due to suspected criminal market manipulation. The request condition applies where a firm has requested information from another firm, which it reasonably believes holds information that may assist it in taking "relevant action", including preventing, detecting or investigating economic crime.

    Read more.
  • UK FCA findings on market soundings in UK equity capital markets
    20 April 2026

    The UK Financial Conduct Authority (FCA) has published findings from its multi‑firm review examining the impact of market soundings on market quality in UK equity capital market (ECM) transactions. The review analysed data from 63 UK equity and equity linked transactions conducted by five wholesale banks between January 2023 and June 2025. The FCA found that trading volumes fell by an average of 13% during market sounding periods but did not observe material impacts on other market quality metrics, including effective and quoted spreads and market depth. On average, 33 investors were market sounded per transaction, with one instance approaching nearly 90 recipients; however, transactions that sounded above average numbers of recipients did not meaningfully increase overall demand or oversubscription after launch.

    While the FCA does not prescribe limits on the number of market sounding recipients, it notes that the risk of inside information leakage may increase as the scale or duration of a market sounding grows and suggests firms consider whether their policies and procedures adequately reflect this. The FCA will continue to engage with banks and other market participants through supervisory work. In addition, the FCA sought feedback on Article 11 of the UK Market Abuse Regulation (MAR) with some banks suggesting improvements, including closer alignment with the EU market soundings regime and reduced record keeping requirements. The FCA will consider this feedback when assessing any future changes to UK MAR.
  • AMLA consults on group-wide requirements and guidelines for BWRAs
    16 April 2026

    The EU Authority for Anti‑Money Laundering and Countering the Financing of Terrorism (AMLA) has launched two consultations on draft measures setting out requirements for business‑wide risk assessments (BWRAs) and group‑wide anti-money laundering and countering the financing of terrorism (AML/CFT) frameworks under the EU Anti‑Money Laundering Regulation (AMLR).

    The first consultation specifies draft regulatory technical standards (RTS) under Articles 16(4) and 17(3) of the AMLR, setting minimum standards for the design and implementation of group‑wide AML/CFT frameworks. They address organisational aspects of group wide AML/CFT requirements, provisions on information sharing within groups, criteria for identifying the parent undertaking in the Union where multiple obliged entities are linked to a third country head office, and the extension of group wide requirements to structures other than groups (which is particularly relevant to the non financial sector). The draft RTS also cover additional measures and requirements where branches or subsidiaries operate in third countries. AMLA proposes a single set of RTS to cover both Article 16(4) and Article 17(3) mandates. The deadline for comments is 15 June, with a public hearing scheduled for 20 May. Feedback will be considered with the final draft RTS due to be submitted by 30 September.

    Read more.
  • UK OFSI strategy for 2026–2029
    15 April 2026

    The UK Office of Financial Sanctions Implementation (OFSI) has published its strategy for 2026–2029. The strategy is based around the "Promote, Enable, Respond and Change" (PERC) framework:
    • Promote: To shape expectations and set the standard, OFSI will run targeted campaigns for priority sectors; publish clear guidance products and assessments showing what non-compliance is and how to avoid it; and work with domestic and international regulators to promote consistency. "Promote" key performance indicators (KPIs) include sector-specific engagement campaigns and delivering joint or co-branded public output (such as joint guidance, public statements, case studies or advisories) with international partners on a quarterly basis.
    • Enable: OFSI will remove friction for legitimate activity and support sanctions compliance behaviour that is fast, predictable and scalable by encouraging early engagement from firms to address risks or uncertainties, providing direct, practical compliance advice on complex scenarios, and maintaining an effective and regularly updated licensing offer with high, publicised service standards. Engagement will be modern and digital by default, including online services, reporting and forms, supported by enhanced data use, data sharing and AI enabled workflows. The "enable" KPI is to close 50% of licensing cases within six months.

    Read more.
  • UK OFSI extends deadline for call for evidence on ownership and control test
    13 April 2026

    The UK government, through the UK Office of Financial Sanctions Implementation (OFSI), has updated its webpage, extending the deadline for responses to its call for evidence on the application of the ownership and control test under the UK Financial Sanctions Regulations. The deadline for responses has been extended from 11:59pm on 13 April to 11:59pm on 20 April.
  • UK FCA findings from multi-firm review on customer due diligence
    8 April 2026

    The UK Financial Conduct Authority (FCA) has published findings of a multi‑firm review of customer due diligence (CDD), enhanced due diligence (EDD) and ongoing monitoring controls, setting out examples of good and poor practice for firms. The FCA assessed CDD systems and controls through a questionnaire, a desk-based review of policies and procedures, customer file reviews and interviews with staff at firms.

    Key findings include:
    • Policies and procedures: Stronger firms demonstrated clear distinctions between standard CDD and EDD, applying risk based approaches to higher risk customers, including politically exposed persons. However, weaknesses included unclear guidance on additional EDD measures, review frequency and how staff should identify and verify customers who cannot provide standard forms of identification. In some cases, firms failed to follow their own policies and procedures, including in relation to periodic customer reviews.

    Read more.
  • UK FCA annual work programme 2026/27
    26 March 2026

    The UK Financial Conduct Authority (FCA) has published its annual work programme for 2026/27 setting out its planned activity for the second year of its five-year strategy. The programme is structured around the following four strategic priorities:
    • Being a smarter regulator: to improve regulatory efficiency and proportionality, the FCA will continue to invest in digital, data and AI capabilities, reduce administrative burdens by simplifying rules and streamlining data returns (including removing three regular returns in April), and improve the authorisation process by further reducing authorisation timelines and continuing to report against new, shorter voluntary targets. In a press release published on the same day, the FCA announced it is developing a new internal AI-enabled authorisation tool, integrated into its existing systems. The FCA will also use generative AI to review documents received from firms, which, following successful testing, it will begin rolling out more widely across authorisations and supervision.

    Read more.
  • The draft Money Laundering and Terrorist Financing (Amendment) Regulations 2026
    26 March 2026

    The draft Money Laundering and Terrorist Financing (Amendment) Regulations 2026 were laid before UK Parliament, alongside a draft explanatory memorandum. The draft Regulations propose amendments to the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLRs) to implement the government's consultation response to its 2024 consultation on improving the effectiveness of the MLRs. The amendments aim to strengthen the UK's anti-money laundering and counterterrorist financing (AML/CTF) regime and ensure maintained compliance with Financial Action Task Force standards.

    Following feedback to the technical consultation on the draft Regulations in September 2025, the government has made a number of targeted changes, including:
    • Pooled client accounts (PCAs): clarifying that banks may continue to apply a simplified, risk-based approach to PCAs where the PCA holder is: (i) subject to the MLRs or equivalent overseas regimes; (ii) the business relationship with the PCA-holder presents a low risk of money laundering and terrorist financing; and (iii) information on the identity of the underlying customers is available on request to the PCA-holder. Additional clarifications are also made.

    Read more.
  • UK FCA statement highlights risks when dealing with unregulated lenders
    20 March 2026

    The UK Financial Conduct Authority (FCA) has published a statement reminding regulated firms of the risks when dealing with unregulated lenders and other "Annex 1" firms. Annex 1 firms are registered with the FCA solely for anti‑money laundering (AML) purposes and are not subject to the FCA's wider regulatory rulebook. The FCA reminds regulated firms that Annex 1 firms are not authorised under the Financial Services and Markets Act 2000, meaning that the FCA's wider conduct rules do not apply to them and their customers do not have access to the UK Financial Ombudsman Service (FOS).

    The FCA therefore expects regulated firms to carry out robust due diligence, in line with legislative requirements, to understand the firm's business. This includes seeking direct confirmation from the Annex 1 firm of its registration status, conducting independent checks of information provided by the Annex 1 firm, and understanding and managing any associated risks, including those identified in the 2025 National Risk Assessment. The FCA also notes that it is aware of some cases where consumers have been encouraged to set up limited companies to access lending, such as unregulated bridging finance, from Annex 1 firms. The FCA emphasises the importance of consumers being aware that FOS protections will not apply if issues arise in these cases.
  • AMLA launches data collection exercise to test risk assessment models
    16 March 2026

    The EU Authority for Anti-Money Laundering and Countering the Financing of Terrorism (AMLA) has launched a data collection and testing exercise aimed at testing and calibrating its risk assessment models for credit and financial institutions. The exercise will support the selection, in 2027, of up to 40 entities for AMLA's direct supervision from 2028, and the development of a consistent, EU‑wide methodology for assessing money laundering and terrorist financing risks. Participation is limited to entities already notified by their national competent authorities. AMLA has published a reporting package, including an interpretative note, reporting template and recording and slides from a webinar explaining the requirements and next steps. Participating firms are required to submit data by 22 April.
  • UK Home Office fraud strategy 2026 to 2029
    9 March 2026

    The UK Home Office has published its updated fraud strategy for 2026–29, setting out the government's new approach to tackling fraud. It explains how the UK intends to disrupt the methods used by criminals, strengthen protections for the public and businesses, and improve how victims are supported. The strategy is split into three pillars:
    • Disrupt: cutting off the tools, technologies and platforms used by criminals, including launching the Online Crime Centre (a new capability that will bring together law enforcement, intelligence agencies and industry expertise to identify and dismantle fraud networks) and strengthening international partnerships. Amongst the initiatives seeking to prevent the abuse of the UK's financial flows, the Home Office will launch a call for evidence focused on unauthorised fraud, the UK Financial Conduct Authority (FCA) will consider examples of practices for preventing APP fraud and money mule activity and will share its recommendations, and HM Treasury will repeal the existing Strong Customer Authentication technical standards, allowing the FCA to incorporate key standards into its rules and adopt a more agile, outcomes-focused approach. Regulating cryptoasset financial services activities is also seen as a crucial step. The government intends to develop metrics for measuring the prevalence of fraudulent activity in financial services, and their performance in removing and/or blocking such activity.

    Read more.
  • UK Home Office launches call for evidence on economic crime sharing
    9 March 2026

    The UK Home Office has launched a call for evidence on the current economic crime information sharing system, seeking views on how existing data sharing gateways used to detect, prevent, investigate and disrupt economic crime can be improved. The call for evidence focuses on identifying legal, operational, and cultural barriers to effective data sharing, as well as opportunities to strengthen the system through reform across the public and private sectors. The scope of this project covers information sharing in relation to any economic crime activity, including fraud, money laundering, corruption and asset recovery which is likely to be interchangeable with information shared on the underlying offences to money laundering. The deadline for comments is 18 May.
  • FATF targeted report on stablecoins and unhosted wallets
    3 March 2026

    The Financial Action Task Force (FATF) has issued a targeted report setting out the money laundering (ML), terrorist financing (TF) and proliferation financing (PF) risks and vulnerabilities related to stablecoins and unhosted wallets, particularly during peer-to-peer (P2P) transactions. In addition, the report identifies and shares a range of good practices that could be implemented by jurisdictions and the private sector to mitigate these risks and makes recommendations for implementation.

    The report highlights that only a limited number of jurisdictions have implemented targeted regulatory frameworks for entities operating within the stablecoins ecosystem, explicitly taking into account the features that distinguish stablecoins from other virtual assets. While the FATF Standards do not require jurisdictions to adopt regulatory frameworks for stablecoin arrangements beyond those already applicable to virtual asset service providers, the FATF urges countries to recognise the specific ML/TF/PF risks associated with stablecoins and to implement proportionate and effective mitigating measures that reflect their distinct characteristics.

    FATF recommends that jurisdictions should apply Recommendation 15 to all relevant entities involved in stablecoin arrangements, ensuring that they are subject to clear, enforceable ML/TF obligations. Jurisdictions should also define the roles and responsibilities of all participants throughout the stablecoin ecosystem and impose appropriate ML/TF obligations using a risk-based approach.

    Read more.
  • HMT guidance on using digital identities with the UK Money Laundering Regulations
    26 February 2026

    HM Treasury and the Department for Science, Innovation and Technology have jointly published guidance setting out how entities regulated under the UK Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLRs) can use digital verification services for customer due diligence checks. Under the MLRs, banks and other regulated entities must establish policies, controls and procedures to mitigate the risks of money laundering and terrorist financing. These include customer due diligence measures to verify the identity of customers and understand the purpose behind transactions. Digital identity services which are certified against the trust framework and on the digital verification services register can be used by regulated entities as part of their customer due diligence processes.

    Specifically, for individuals, entities can fulfil their obligations under the MLRs by verifying a customer's identity using certified and registered digital identity services. Entities may also use certified and registered digital identity services to fulfil their obligations regarding the verification of company directors. Regulated entities are reminded that they should continue to make their own assessment of a customer's risk and apply enhanced due diligence measures accordingly. While digital identities may be used for identification and verification purposes, entities should not assume that digital identities fulfil all aspects of customer due diligence. Regulated entities will also remain ultimately liable for any failures to apply customer due diligence measures appropriately when using digital identity services. Entities should also ensure that services can meet the required record-retention requirements under the MLRs. The new guidance supplements but does not supersede obligations under the MLRs.
  • ESMA consults on streamlining MAR guidelines
    19 February 2026

    The European Securities and Markets Authority (ESMA) has launched a consultation on proposed amendments to its guidelines on delay in the disclosure of inside information, under the Market Abuse Regulation (MAR). ESMA aims to streamline requirements and reduce administrative burdens for issuers. The proposals aim to align the guidelines with the changes introduced by the EU Listing Act to ensure compatibility with the new regime. Specifically, under the Act, from June onwards, issuers will no longer be required to immediately disclose inside information relating to protracted processes before those processes are completed. Consequently, ESMA proposes removing the existing references to legitimate interests that are linked to such protracted processes. It also introduces additional legitimate interests for delayed disclosure, including where a public authority requests non-disclosure of inside information, where additional time is needed to collect information, or where the issuer is involved in multiple similar procurement processes. ESMA also proposes deleting the section about the "no misleading the public" condition from the guidelines, reflecting its removal from MAR, and replacing it with the requirement that any delayed disclosure must not contradict the issuer's most recent public announcement on the same matter. The deadline for responses is 29 April, with a final report expected in Q4.
  • UK government call for evidence on ownership and control test
    16 February 2026

    The UK government, through the UK Office of Financial Sanctions Implementation (OFSI), has launched a call for evidence on the application of the ownership and control test under the UK Financial Sanctions Regulations. The OFSI seeks industry input on how the test operates in practice and where firms experience challenges in implementing the regulations. Specifically, firms are requested to share evidence and practical examples of: (i) how often "hypothetical control" is present in real financial sanctions cases; (ii) its effects on compliance costs, legal risk and business decision‑making including de‑risking; and (iii) whether existing legal concepts and typologies of control are helpful in applying ownership and control regulations. OFSI states the evidence gathered will inform its assessment of whether the current approach is clear, effective and proportionate, with the aim of ensuring sanctions remain tough on those they target while workable for legitimate businesses. The call for evidence is open to businesses, financial institutions, legal and compliance professionals and other interested parties. The deadline for responses is 11:59 pm on 13 April.
  • EC publishes draft Delegated Regulations under AMLD6 and AMLR
    13 February 2026

    The European Commission (EC) has published two new webpages announcing the forthcoming adoption of two draft Delegated Regulations. The first, under Directive (EU) 2024/1640 (AMLD6), will set out the indicators for assessing the gravity of failures by member states to report adequate, accurate and up-to-date information to the central registers, including in cases of repeated failures.

    The second, under Regulation (EU) 2024/1624 (AMLR), will define the categories of breaches subject to penalties, liable persons, indicators of the gravity of breaches and criteria to consider when setting the level of penalties of beneficial ownership transparency requirements. The texts of both Delegated Regulations have not yet been published and no consultation details have yet been provided. The EC plans to adopt them in Q3.
  • FATF updates regarding high-risk jurisdictions and jurisdictions under increased monitoring
    13 February 2026

    The Financial Action Task Force (FATF) has published updates on high-risk jurisdictions and jurisdictions under increased monitoring. There are no changes to the high-risk jurisdictions, although the FATF notes where improvement is still required and confirms it may consider countermeasures if insufficient progress is made by June. For the jurisdictions under increased monitoring, two jurisdictions have been added, bringing the total number of jurisdictions under increased monitoring to 22. The FATF also remarks on improvements for certain jurisdictions and any identified next steps.
  • UK OFSI updates financial sanctions enforcement and monetary penalties guidance
    9 February 2026

    The UK Office of Financial Sanctions Implementation (OFSI) has published updated financial sanctions enforcement and monetary penalties guidance following HM Treasury's (HMT) 2025 consultation on proposed reforms to the OFSI's civil enforcement processes. A consultation response was published in January confirming that the reforms would proceed, which we covered previously here.

    OFSI has updated the guidance to reflect the enhancements set out in Chapter 4 on the new Early Account Scheme (EAS), Chapter 5 on the revised case assessment framework and Chapter 6 on the updated methodology for the monetary penalty process, including the incorporation of the EAS discount, the new voluntary disclosure and cooperation discount and the settlement scheme. Chapter 7 introduces guidance on financial hardship, explaining how OFSI may take this into account in exceptional circumstances. Chapter 13 is supplementary to Chapters 6 and 7 on monetary penalties and sets out how penalties will be imposed for certain cases dealt with by means of a fixed monetary penalty. Additional amendments have been made throughout to improve procedural clarity. These key changes are effective immediately.
  • EU AMLA launches suite of consultation papers on draft RTS under EU AML package
    9 February 2026

    The EU Authority for Anti-Money Laundering and Countering the Financing of Terrorism (AMLA) has published three consultation papers on the following draft regulatory technical standards (RTS) under the EU AML package (for more background, you may like to read our article "The AML revolution: Are you ready?"):
    • Draft RTS on pecuniary sanctions, administrative measures and periodic penalty payments under Article 53(10) of Directive (EU) 2024/1640 (AMLD 6). The RTS specify the indicators to assess the gravity of breaches, criteria for determining the level of pecuniary sanctions or applying administrative measures, and a methodology for the imposition of periodic penalty payments, including their frequency. They aim to ensure that the same breach is assessed in the same way by all supervisors in all Member States, and that the resulting enforcement measures are proportionate, effective and dissuasive. The deadline for comments is 9 March.
    • Draft RTS on customer due diligence (CDD) under Article 28(1) of Regulation (EU) 2024/1624 (AMLR) specifying in detail how CDD requirements should be applied, including the information and documents to be collected. The deadline for comments is 8 May.

    Read more.
  • AMLA's first single programming document for 2026-2028
    4 February 2026

    The Authority for Anti-Money Laundering and Countering the Financing of Terrorism (AMLA) has published its first single programming document (SPD) for 2026-2028, setting out its strategic priorities and providing transparency on AMLA's timelines as it transitions to full operational capacity. AMLA's key objectives include finalising the Single Rulebook, driving supervisory convergence and enhancing cooperation between Financial Intelligence Units (FIUs). These are translated into five workstreams that will shape AMLA's work in 2026, including delivering regulatory mandates, advancing direct supervision, operationalising the FIU framework, preparing the foundations for indirect supervision and oversight, and developing AMLA's risk frameworks. The SPD also provides a digital roadmap for 2026-2028 which focuses on three priorities including building state-of-the-art digital solutions, taking over and modernising mission-critical systems, and positioning AMLA as a leader in data analytics and innovation. AMLA also seeks to systematically integrate AI in the development of all its operations. AMLA has separately published an explainer of the SPD and a list of 2026 mandates.
  • UK JMLSG final amendments to Part 1 of AML/CFT guidance
    4 February 2026

    The UK Joint Money Laundering Steering Group (JMLSG) has published final amendments to Part I of its anti-money laundering and counter-terrorist financing (AML/CFT) guidance for the financial services sector. This follows the consultation in November 2025. The amendments are made to: (i) chapter 3, related to guidance on the standing of the MLRO, and on monitoring the effectiveness of money laundering controls; and (ii) chapter 6, relating to guidance on subject access requests in cases where a suspicious report has been made. The revisions have been submitted to HM Treasury for Ministerial approval.
  • New regime pages for the UK Sanctions List
    2 February 2026

    The UK Office of Financial Sanctions Implementation (OFSI) has published new regime pages following the closure of the OFSI Consolidated List of Asset Freeze Targets, which is now replaced with the UK Sanctions List (UKSL). The UKSL became the sole official source for UK sanctions designations from January. The new regime pages will host future sanctions notices, covering all changes to designations made under each regime on the UKSL. The old financial sanctions regime pages, while they will remain available for reference, will no longer be updated.
  • HMT consultation response on reforms to OFSI civil enforcement processes
    29 January 2026

    HM Treasury (HMT) has published a consultation response and blog on proposed reforms to the UK Office of Financial Sanctions Implementation's (OFSI) civil enforcement processes. The reforms aim to increase efficiency in resolving enforcement cases and would apply solely to OFSI's civil enforcement powers concerning financial sanctions breaches, including Russia-related designated person asset reporting. They do not apply to criminal enforcement or non-financial sanctions. Following feedback to its July 2025 consultation, the OFSI confirms it will proceed with all proposals but with the following improvements:
    • Additional case assessment guidance, including a new case assessment matrix and a Voluntary Disclosure and Co‑operation discount of up to 30% of the baseline penalty.
    • 20% baseline penalty discount for subjects who settle under the new settlement scheme.

    Read more.
  • UK OFSI and partners crack down on the abuse of cryptoassets
    28 January 2026

    The UK Office of Financial Sanctions Implementation (OFSI) has published a blog confirming that it is working closely with UK law enforcement and regulatory partners to combat the abuse of cryptoassets and associated money laundering activities. OFSI has joined forces with the Crypto Cash Fusion Cell (CCFC), a pilot, multi-agency initiative bringing together the UK National Crime Agency, the Metropolitan Police Service, His Majesty's Revenue and Customs, the UK Financial Conduct Authority, City of London Police and OFSI, to target criminal funds linked to sanctions offences.

    Through this collaboration, OFSI shared detailed intelligence with the CCFC to enable joint working against specific, prioritised targets. This led to action against potential breaches of financial sanctions involving cryptoassets by UK-based individuals. OFSI wants the sector to know that the use of cryptoassets to evade sanctions will be treated no differently to the exploitation of traditional currencies.
  • EC call for evidence on action plan for fighting online fraud
    26 January 2026
    The European Commission has issued a call for evidence on its forthcoming action plan to combat online fraud committed through the use of technology (whether online or by telephone). The initiative seeks to build on existing frameworks which already establish comprehensive anti-fraud measures, including the Payment Services Directive, the Instant Payments Regulation and the Digital Services Act. The plan aims to reduce the occurrence and impact of online fraud across the EU by reinforcing coordination, enhancing victim support and improving cross-border and multi-stakeholder cooperation. Its primary objective is to establish a more integrated approach to tackling online fraud. This includes strengthening the EU's 'follow-the-money' approach for detecting, tracing and disrupting fraud proceeds that are channelled through payment accounts, e-money and increasingly, crypto-asset transfers, leveraging EU requirements on supplying accompanying information with transfers of funds and certain crypto-assets. The deadline for feedback is 13 February.
  • AMLA data collection exercise to test risk assessment models for the financial sector
    26 January 2026

    The EU Authority for Anti‑Money Laundering and Countering the Financing of Terrorism (AMLA) has announced a data‑collection exercise expected in March to test and calibrate its risk‑assessment models. These models will inform the 2027 selection of up to 40 entities for AMLA's direct supervision beginning in 2028 and support consistent money laundering risk assessments by supervisors across the EU. The exercise, conducted with national supervisors and the private sector, will involve both financial institutions potentially eligible for direct supervision and a representative sample of entities likely to remain nationally supervised. National supervisors of both groups have been notified by the AMLA of those selected to participate in the exercise. After validating and calibrating the models in full, AMLA will finalise the list of eligible entities for direct supervision. In early 2027, national supervisors will collect data from those entities to inform AMLA's final supervisory selection. AMLA has also published an accompanying explainer on its direct supervision framework, available here.
  • UK regulators publish joint 2025 CBEST thematic report
    21 January 2026

    The Bank of England, UK Prudential Regulation Authority and UK Financial Conduct Authority have published their 2025 annual CBEST thematic report. CBEST is a threat-led penetration testing assessment framework of cyber resilience, helping regulators, firms and financial market infrastructures (FMIs) identify vulnerabilities and take remedial action. This report summarises insights from recent CBEST assessments conducted across firms and FMIs. While it does not introduce any new or additional regulatory expectations, it articulates gaps, some of them foundational, observed in firms' and FMIs' cyber defences.

    Key messages for firms and FMIs to consider include:
    • To reduce the likelihood of severe cyberattacks, firms and FMIs should harden operating systems by patching vulnerabilities and securely configuring key applications.
    • The impact of unauthorised access to sensitive systems and information can be reduced by strengthening credentials management, enforcing strong passwords, considering the use of multi-factor authentication, preventing or detecting insecure credential storage and through appropriate segmentation of networks.

    ​Read more.
  • FMSB publishes 2026 workplan
    14 January 2026

    The Financial Markets Standards Board has published its 2026 workplan. The workplan covers a wide range of areas in relation to wholesale financial markets, and in 2026 the Board sets out the following focus topics:
    • In relation to market practices, work is being progressed on pre-hedging, grey market trading, market quotation mechanisms, conduct risks around risk management transactions for new issuances, and price discovery.
    • In relation to electronic trading and technology, the relevant committee will be looking at market-facing applications of AI and potentially the application of model risk management frameworks to electronic trading algorithms.

    Read more.
  • UK FCA and PSR joint response to HMT's 2024 recommendations on payments regulation
    16 December 2025

    The UK Financial Conduct Authority (FCA) and UK Payments Systems Regulator (PSR) have issued a joint letter to HM Treasury (HMT) (dated 11 November) providing an update on their progress against the 2024 recommendations HMT set for payments regulation and outlining focus areas through to 2026.

    Key forward-looking priorities include:
    • Co-ordination - the regulators set out how they have been working in an increasingly collaborative way to ease congestion in payments regulation.
    • Open banking and open finance – the FCA has established a new department incorporating FCA and PSR capabilities, replacing the Joint Regulatory Oversight Committee (JROC) and streamlining decision-making for open banking and open finance. The FCA is working with industry to establish a future entity for open banking ahead of developing the statutory instrument with HMT and subsequently the long-term regulatory framework for open banking. In addition, the FCA has launched the smart data accelerator, with applications currently open for two prioritised open finance use cases in SME lending and mortgages. The FCA will publish a roadmap for this in early 2026, with regulatory foundations in place during 2027. The FCA is also collaborating with the Department for Business and Trade on cross-sector data sharing.

    Read more.
  • Changes to EU list of high-risk third countries with strategic AML/CTF framework deficiencies
    3 December 2025

    The European Commission (EC) has announced that it has listed Russia as a high-risk country with strategic deficiencies in its anti-money laundering and counter-terrorist financing frameworks (AML/CFT) pursuant to the EU's directive on anti-money laundering and terrorist financing (AMLD IV). This follows Delegated Regulation (EU) 2025/1393, adopted in July, which committed the EC to conclude a review of third countries not listed by the Financial Action Task Force (FATF), but whose membership is suspended. This included Russia which, following a technical assessment, the EC concludes meets the criteria to be designated as a high-risk third country. The EC has therefore adopted a delegated regulation adding Russia to its list of high-risk jurisdictions presenting strategic deficiencies in their national AML/CFT regimes. On the following day, 4 December, the EC made a further announcement that it has updated its list of high-risk jurisdictions presenting strategic deficiencies in their national AML/CFT regimes following the decisions taken at the FATF and its list of 'Jurisdictions under Increased Monitoring' ('grey list'), following the plenaries of June and October 2025. The EU has adopted a further delegated regulation under AMLD IV adding new third-country jurisdictions (Bolivia and the British Virgin Islands) to the list of jurisdictions with strategic deficiencies and delisting a number of others (Burkina Faso, Mali, Mozambique, Nigeria, South Africa and Tanzania). The delegated regulations will enter into force after scrutiny and non-objection of the European Parliament and the Council within a period of one month (which can be extended by a further month). EU entities covered by the EU's AML framework are required to apply enhanced vigilance in transactions involving such high-risk jurisdictions.