PIMFA
FINANCIAL CRIME
Financial Crime is broadly any criminal conduct relating to money or financial services, including, for example, fraud, money laundering, the misuse of information (such as insider trading), bribery and corruption, handling the proceeds of crime, financing terrorism, or cybercrime. According to the Office of National Statistics, there were c.4.2 million fraud incidents in England and Wales during the year to March 2025 a 31% rise on the previous year.
The PIMFA Financial Crime Committee facilitates discussion across all significant matters of financial crime, ensuring that member firms are kept fully informed and compliant with legislative and regulatory developments and are provided with the latest intelligence, approaches and tools to combat financial crime effectively.
The guide in collaboration with Avyse offers practical, risk-based examples and recommendations tailored to the specific structures, client profiles, and transaction patterns typically found in the investment and wealth management sector
latest news
Joint Money Laundering Steering Group – Revisions to Part I of Guidance
The Joint Money Laundering Steering Group (JMLSG) has published final amendments to various paragraphs within Part I of its Guidance.
These revisions concern Paragraphs 2.9, 5.2.4A, 5.3.94A, 5.3.99, 5.3.142, and Annex 5-V and have been submitted to HM Treasury for Ministerial approval.
Read more information here
FCA Financial Crime Risks: Increased scrutiny to Annex 1 firms
The FCA recently issued a statement about financial crime risks among Annex 1 firms.
The FCA notes the March 2026 statement to regulated firms about such risks and advises that the regulator is closely scrutinising applications to register as an Annex 1 firm, with firms needing to clearly demonstrate that they can comply with the money laundering regulations.
Read more information here.
FCA Findings: Asset Management and alternative firms’ financial crime controls – Avyse Partners Regulatory Gap Analysis
Following on from the FCA’s publication of its findings of a review of financial crime controls across 242 asset management and alternatives firms, our associates, Avyse Partners, have distilled the FCA’s findings into a Regulatory Gap Analysis covering eight key themes – from business profile and risk assessments through to governance, screening and training – with regulatory references and self-assessment questions for firms to challenge their own control frameworks.
Access the Avyse paper here
FCA Wider Implications Framework Annual Report 2025/26
The FCA has published the Wider Implications Framework Annual Report for 2025-26 and notes key areas of collaboration:
- Advice Guidance Boundary Review
- Consumer Duty
- APP Fraud
- Pensions Value for Money Framework
- Motor Finance Commission Redress
Updated Terms of Reference have also been published.
Read the full report here
FCA Findings: Asset Management and Alternative Firms’ Financial Crime Controls
Following engagement with asset management and alternatives firms, the FCA has published findings including examples of good and poor practice.
- Areas covered in the findings include screening, governance, due diligence, ongoing monitoring, and risk assessments
- The FCA note good practice examples, such as establishing review cycles for business wide risk assessments to ensure accuracy and adequate policies, controls, and procedures in place to mitigate identified risks
- Poor practices have also been highlighted, e.g., the FCA state that c40% of all firms outsourced some part of their financial crime compliance function, however, only 36% had full oversight over third party AML onboarding processes
The publication aims to help firms reflect on the financial crime risks inherent in their business models, and how well their control frameworks are designed to identify, manage and mitigate those risks.
Read the full findings here
From Tick Box to Decision Tool – Rethinking Financial Crime Risk Assessments
Read this article from the PIMFA Journal #33 by Priya Giuliani at HKA about Rethinking Financial Crime Risk Assessments
