Insights

Briefings for the UK financial crime community.

Concise analysis on the UK's changing anti-money laundering, counter-terrorist financing and sanctions regimes — written by the practitioners who advise on them. We publish when there is something worth saying, not to a content calendar.

Consultation

12 June 2026

MLR 2017 reform: what to expect from the Treasury's call for evidence

HM Treasury has invited industry views on simplified due diligence thresholds, pooled client account treatment, the cryptoasset travel-rule perimeter and the future of the high value dealer regime. Firms should not read the exercise as a signal of deregulation — the direction of travel remains toward sharper risk-based expectation, clearer beneficial ownership evidence and faster information-sharing between the regulated sector and law enforcement. We set out where firms should focus their response and the drafting traps to avoid when supporting a change in the primary framework.

FCA

28 May 2026

The 2026 Dear CEO letter: reading between the lines

The FCA has published its most detailed expectations to date for Annex I financial institutions. The letter escalates language on governance and management information, calibration and coverage of transaction monitoring rules, beneficial ownership evidence for corporate customers with layered offshore structures, and the treatment of Politically Exposed Persons under the revised Regulation 35. We unpack each theme and identify the specific artefacts a supervisor will now expect to see in a first meeting.

OFSI

14 May 2026

Russia sanctions: refreshed guidance on ownership and control

OFSI's updated guidance clarifies aggregation of holdings across designated persons for the purposes of the 50 per cent ownership test, and raises the evidential bar for the alternative control test where influence is exercised through non-equity means such as board appointment rights, financing covenants or shareholder agreements. Legal, property, corporate services and private banking firms should re-test EDD templates and consider whether historic files require refresh in light of the tighter standard.

Crypto

02 May 2026

Registering as a cryptoasset business: the ten most common gaps

Drawing on our authorisation work with UK cryptoasset exchange and custodian wallet providers, we identify the ten weaknesses that most frequently trigger further information requests or applicant withdrawal. Recurring themes include an under-developed firm-wide risk assessment, monitoring coverage that fails to reflect on-chain typologies such as mixer usage and peel chains, weak evidence for the source of wealth of high-net-worth customers, and governance structures that place the MLRO too far from the executive.

Property

18 April 2026

Estate agents and the Register of Overseas Entities: two years on

The ROE regime introduced by ECTEA 2022 continues to catch out property firms working with foreign buyers and their advisers. We revisit the perimeter — who is caught, when verification is required, what evidence is defensible, how updates and annual filings interact with a live transaction, and where the interaction with HMRC's estate agent supervisory approach creates the greatest exposure — and set out a working checklist for compliance officers in the sector.

Enforcement

05 April 2026

Reading a Final Notice: what recent FCA cases tell us about AML controls

Recent enforcement outcomes across banks, payment institutions and cryptoasset firms point to persistent themes: firm-wide risk assessments that are static rather than dynamic, management information to the board that fails to translate SAR volume into a picture of actual customer risk, transaction monitoring rules whose thresholds were never tested against the firm's own population, and remediation programmes signed off before the underlying root cause was addressed. We synthesise the pattern and the practical inferences a Head of Financial Crime should draw.

NCA

22 March 2026

SARs Reform: what the new information-sharing gateway means in practice

Part 5 of the Economic Crime and Corporate Transparency Act 2023 introduced a gateway allowing firms in the regulated sector to share information for the purposes of preventing, detecting or investigating economic crime. The gateway is permissive rather than mandatory, and the operational conditions — the safeguards, the record-keeping and the interaction with data protection law — must be worked through before a firm can rely on it. We set out a governance framework for firms considering participation and cover the interaction with the ongoing Public-Private Partnership work led by the NCA.

PEPs

08 March 2026

Domestic PEPs after the FCA's Regulation 35 review

The FCA's multi-firm review of the treatment of domestic Politically Exposed Persons concluded that most firms are broadly meeting the revised statutory expectation but identified pockets of over-application, particularly to family members and known close associates. We work through the practical implications for firms operating retail banking, wealth and payment services, and set out how to evidence a proportionate approach to a supervisor without under-mitigating the underlying risk.

Sanctions

24 February 2026

Ownership, control and the trust problem

Where a designated person's interest is held through a trust or a chain of overseas vehicles, the ownership and control analysis becomes materially harder. We look at the interaction between the OFSI guidance, the FATF Recommendation 25 standard on beneficial ownership of legal arrangements and the practical evidence firms can obtain in the time available on a live transaction — and where the honest answer is that the firm cannot proceed with the required level of assurance.