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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

A consumer focus on the Mills Review: What are the main consumer issues that you need to be thinking about?

From PIMFA Journal, Edition #34, Kerry Berchem of Burges Salmon LLP discusses how the Mills Review highlights both the opportunities and risks of AI in financial services. The article focuses on consumer trust, inclusion and protection, while emphasising the need for strong governance to ensure better outcomes as AI becomes increasingly embedded in financial decision-making.

FCA Ensuring Firms are Equipped to Fight Financial Crime

The FCA has issued a newsletter, where Steve Smart (executive director lead for fighting financial crime) highlights information sharing by the regulator to address financial crime, for example:

  • The recently published findings on Money mules activity set out the tactics used by organised criminal groups as well as clear expectations of what firms need to do to counter these threats.
  • The FCA also emphasises the importance of information-sharing and notes the voluntary information-sharing provisions of the Economic Crime and Corporate Transparency Act 2023.

The newsletter also notes that:

  • The FCA plans to consult on proposed updates to the Financial Crime Guide to aid firms in strengthening their systems and controls.
  • The regulator will continue with increased scrutiny on Annex 1 firms having observed an over reliance by such firms on the financial crime controls of their parent company.

Home Office publishes the AMLAR Strategy (2026-2029)

The Anti-Money Laundering and Asset Recovery (AMLAR) Strategy 2026-2029 has now been published on GOV.UK. The strategy sets the direction for the UK’s anti-money laundering and asset recovery system over the next 3 years. It defines what the system will prioritise, how partners will work together, and where the government will invest to stay ahead of the threat.

Read the paper here

FCA Financial Crime: Protecting the Hive

The FCA has published a speech by Steve Smart (executive director of enforcement and market oversight).

The speech notes:

  • The extension of the FCA’s scope to include anti-money laundering (AML) supervision of the legal and accounting sectors.
  • The regulator’s focus on targeting firms enabling financial crime and minimising unnecessary burden on compliant firms.
  • Partnership, communication and trust are essential to make the system harder for criminals to exploit.

Read the full speech here

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.

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